Amendment of Environmental Management Programmes for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC

Marine and Coastal Ecology Assessment

Prepared for:

SLR Environmental Consulting (Pty) Ltd

On behalf of:

Alexkor RMC Pooling and Sharing JV

October 2017

Amendment of Environmental Management Programmes for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC

MARINE AND COASTAL ECOLOGY ASSESSMENT

Prepared for

SLR Environmental Consulting (Pty) Ltd

On behalf of:

Alexkor RMC Pooling and Sharing JV

Prepared by

Andrea Pulfrich Pisces Environmental Services (Pty) Ltd

September 2017

Contact Details:

Andrea Pulfrich Pisces Environmental Services PO Box 31228, Tokai 7966, South Africa, Tel: +27 21 782 9553 E-mail: [email protected] Website: www.pisces.co.za

MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC

TABLE OF CONTENTS

1. GENERAL INTRODUCTION ...... 1

1.1. Scope of Work ...... 1

1.2. Approach to the Study ...... 2

1.2.1 Assumptions, Limitations and Information Gaps ...... 2 1.2.2 Impact Assessment Methodology ...... 3 2. DESCRIPTION OF THE PROPOSED PROJECT ...... 6

2.1. Introduction...... 6

2.2. Marine Prospecting ...... 9

2.2.1 Geophysical Surveys ...... 9 2.2.2 Sampling ...... 10 2.3. Marine Mining ...... 11

2.3.1 Boat- and Shore-Based Diver Assisted Mining ...... 11 2.3.1.1 Boat-based diver assisted mining ...... 11 2.3.1.2 Shore-based diver assisted mining ...... 12 2.3.2 Coffer Dam Mining ...... 13 2.3.3 Inter-Tidal Beach Mining Using Mobile Pump Units ...... 14 2.3.4 Large Vessel Mining ...... 15 2.3.4.1 Vessel-based remote dredge pump mining ...... 15 2.3.4.2 Vessel-based airlift mining...... 15 2.3.4.3 Vessel-based remote crawler mining ...... 17 3. DESCRIPTION OF THE BASELINE MARINE ENVIRONMENT ...... 18

3.1. Geophysical Characteristics ...... 18

3.1.1 Bathymetry ...... 18 3.1.2 Coastal and Inner-shelf Geology and Seabed Geomorphology ...... 19 3.2. Biophysical Characteristics ...... 20

3.2.1 Wind Patterns ...... 20 3.2.2 Large-Scale Circulation and Coastal Currents ...... 22 3.2.3 Waves and Tides ...... 23 3.2.4 Water ...... 23 3.2.5 Upwelling & Plankton Production ...... 25 3.2.6 Organic Inputs ...... 25 3.2.7 Low Oxygen Events ...... 26 3.2.8 Turbidity ...... 27 3.3. The Biological Environment ...... 30

3.3.1 Sandy and Unconsolidated Substrate Habitats and Biota ...... 31

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3.3.1.1 Intertidal Sandy Beaches ...... 31 3.3.1.2 Nearshore and Offshore unconsolidated habitats ...... 34 3.3.2 Rocky Substrate Habitats and Biota ...... 37 3.3.2.1 Intertidal Rocky Shores ...... 37 3.3.2.2 Rocky Subtidal Habitat and Kelp Beds...... 40 3.3.2.3 Deep-water coral communities ...... 42 3.3.3 The Water Body ...... 45 3.3.3.1 Demersal Fish Species ...... 45 Plankton ...... 46 3.3.3.2 Pelagic Communities ...... 47 Cephalopods ...... 48 Pelagic Fish ...... 48 Turtles ...... 53 Seabirds ...... 55 Marine Mammals ...... 57 3.4. Other Uses of the Area ...... 67

3.4.1 Beneficial Uses ...... 67 3.4.1.1 Diamond Mining ...... 67 3.4.1.2 Hydrocarbons ...... 67 3.4.1.3 Kelp Collecting ...... 68 3.4.1.4 Large-scale Commercial Fisheries ...... 72 3.4.1.5 Rock Lobster Fishery ...... 72 3.4.1.6 Recreational Fisheries ...... 73 3.4.1.7 Mariculture ...... 74 3.4.2 Conservation Areas and Marine Protected Areas ...... 74 3.4.3 Threat Status and Vulnerable Marine Ecosystems ...... 77 4. LEGISLATIVE REQUIREMENTS ...... 82

4.1. National Legislation ...... 82

4.2. International Marine Pollution Conventions ...... 82

4.3. Other South African Legislation ...... 82

5. ASSESSMENT OF IMPACTS OF COASTAL AND OFFSHORE MINING ON MARINE FAUNA ...... 84

5.1. Identification of Impacts ...... 84

5.2. Project Controls ...... 86

5.3. Assessment of Impacts ...... 86

5.3.1 Physical disturbance of benthic habitats ...... 86 5.3.1.1 Disturbance and loss of supratidal habitats and associated biota ...... 86 5.3.1.2 Disturbance and loss of intertidal and shallow subtidal habitats and associated biota ...... 89 5.3.1.3 Physical disturbance of the seabed during prospecting and mining operations in deeper waters ...... 100

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5.3.2 Discharge of tailings from classifiers and on-board treatment plants and redistribution of cofferdam wall sediments ...... 108 5.3.3 Disturbance of marine biota by noise ...... 119 5.3.3.1 Generation of underwater noise ...... 120 5.3.3.2 Physiological injury in response to geophysical surveying ...... 122 5.3.3.3 Behavioural changes and masking of biologically-relevant sounds in marine fauna in response to geophysical surveying and underwater mining noise ...... 123 5.3.3.4 Disturbance and behavioural changes in Marine Fauna in Response to aircraft / helicopter noise ...... 125 5.2.4 Discharge of waste to sea (e.g. deck and machinery space drainage, sewage and galley wastes) and local reduction in water quality ...... 128 5.2.5 Potential loss and discard of equipment ...... 132 5.2.6 Increased Ambient Lighting ...... 134 5.2.7 Accidents and Emergencies ...... 136 5.2.8 Cumulative Impacts ...... 139 6. CONCLUSIONS ...... 141

7. MITIGATIONS AND MANAGEMENT PLAN ...... 143

8. LITERATURE CITED ...... 169

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MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC

ABBREVIATIONS and UNITS

BCLME Benguela Current Large Marine Ecosystem cm centimetres cm/s centimetres per second CITES Convention on International Trade in Endangered Species CMS Centre for Marine Studies CSIR Council for Scientific and Industrial Research dB decibell DAFF Department of Agriculture, Forestry and Fisheries DEA Department of Environmental Affairs and Tourism E East EBSA Ecologically or Biologically Significant Area ECOP Environmental Code of Operational Practice EEZ Exclusive Economic Zone EIA Environmental Impact Assessment EMPr Environmental Management Programme FAO Food and Agricultural Organisation g/m2 grams per square metre g C/m2/day grams Carbon per square metre per day GIS Global Information System ha hectares HABs Harmful Algal Blooms Hz Herz IUCN International Union for the Conservation of Nature IWC International Whaling Commission JNCC Joint Nature Conservation Committee kHz kiloHerz km kilometre km2 square kilometre km/h kilometres per hour kts knots MFMR Ministry of Fisheries and Marine Resources (Namibia) MMO Marine Mammal Observer MPA Marine Protected Area MPRDA Mineral and Petroleum Resources Development Act MSY Maximum Sustainable Yield m metres m2 square metres m3 cubic metre mm millimetres m/s metres per second mg/ milligrams per litre nm nautical mile

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N north NE Northeast NDP Namibian Dolphin Project NEMA National Environmental Management Act NNW north-northwest NMMU Nelson Mandela Metropolitain University NOAA National Oceanic and Atmospheric Administration NW north-west PAM Passive Acoustic Monitoring PIM Particulate Inorganic Matter POM Particulate Organic Matter ppm parts per million PRDW Prestedge Retief Dresner Wijnberg PRM Placer Resource Management (Pty) Ltd S south SACW South Atlantic Central Water SADCO Southern Africa Data Centre for Oceanography SANBI South African National Biodiversity Institute SASA South African Sea Area SD Standard Deviation SLR SLR Consulting (South Africa) (Pty) Ltd SPRFMA South Pacific Regional Fisheries Management Authority SST Sea Surface Temperature SSW South-southwest SW south-west tons/km2 tons per square kilometre TAC Total Allowable Catch TSPM Total Suspended Particlate Matter UNEP United Nations Environmental Programme VMEs Vulnerable Marine Ecosystems VOS Voluntary Observing Ships µg micrograms µm micrometre µg/ micrograms per litre µPa micro Pascal °C degrees Centigrade % percent ‰ parts per thousand ~ approximately < less than > greater than

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EXPERTISE AND DECLARATION OF INDEPENDENCE

This report was prepared by Dr Andrea Pulfrich of Pisces Environmental Services (Pty) Ltd. Andrea has a PhD in Fisheries Biology from the Institute for Marine Science at the Christian- Albrechts University, Kiel, Germany.

As Director of Pisces since 1998, Andrea has considerable experience in undertaking specialist environmental impact assessments, baseline and monitoring studies, and Environmental Management Programmes relating to marine diamond mining and dredging, hydrocarbon exploration and thermal/hypersaline effluents. She is a registered Environmental Assessment Practitioner and member of the South African Council for Natural Scientific Professions, South African Institute of Ecologists and Environmental Scientists, and International Association of Impact Assessment (South Africa).

This specialist report was compiled for SLR Environmental Consulting (Pty) Ltd on behalf of Alexkor RMC Pooling and Sharing JV for their use in preparing an Amendment to the Environmental Management Programmes for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC. I do hereby declare that Pisces Environmental Services (Pty) Ltd is financially and otherwise independent of the Applicant and SLR.

Dr Andrea Pulfrich

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MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC

1. GENERAL INTRODUCTION Alexkor RMC Pooling and Sharing Joint Venture (PSJV) holds numerous coastal and offshore marine diamond mining license areas (Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC), covering Sea Concessions 1a, 1b, 1c, 2a, 3a, 4a and 4b, which it actively mines.

Mining activities are currently undertaken in terms of three approved Environmental Management Programmes (EMPRs), as amended (CSIR, 1994; Site Plan, 2008; Myezo, 2013), two of which are applicable to the marine Mining Rights.

The PSJV is in the process of amending its EMPRs for the marine Mining Rights in order to comply with the current requirements of the National Environmental Management Act, 1998 (No. 108 of 1998) (NEMA) and the Environmental Impact Assessment (EIA) Regulations 2014, as amended, and to ensure alignment with each other, all new legislation, environmental standards, as well as internal PSJV Performance Assessment Reports.

SLR Environmental Consulting (Pty) Ltd (SLR), in association with Placer Resource Management (Pty) Ltd (PRM), has been appointed to undertake the EMPR amendment process in terms of the NEMA, and in turn have asked Pisces Environmental Services (Pty) Ltd to provide a specialist assessment report on potential impacts of the proposed mining operations on marine and coastal ecology in the area.

1.1. Scope of Work Following a two-day site visit to the licence areas in late July 2017, this specialist report was compiled as a desktop study on behalf of SLR, for their use in preparing amended EMPRs for the marine Mining Right areas.

The following general terms of reference apply to this specialist study:  Provide a brief description of the prospecting and mining methods.  Provide a description of the baseline marine biology in the project area based on information collected during the site visit, supplemented with information gathered through a review of the peer-reviewed scientific literature, other marine specialist reports undertaken in the region, information sourced from the internet and any available unpublished data. All pertinent characteristics of the marine environment will be described including amongst others the following components:  Local/regional waves, tides and currents;  Surf zone currents and processes;  Nutrients and nearshore water quality;  Turbidity and organic inputs;  Pelagic communities;  Intertidal rocky shore and sandy beach communities;  Shallow subtidal benthic communities;  Marine mammals, turtles and seabirds;  Sensitive and threatened habitats, and threatened or rare marine fauna and flora;  Extractive and non-extractive uses of the area; and

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 Existing impacts and future-use scenarios (including proposed Marine Protected Areas).  Provide a brief description of the relevant legislative and permitting requirements that apply to coastal and shallow-water mining operations.  Review all relevant, available local and international publications and information sources on the disturbances and risks associated with coastal and shallow-water mining operations.  Identify, describe and assess the significance of potential impacts of the prospecting and mining operations on the marine and coastal environment.  Identify practicable mitigation and management measures to reduce any negative impacts and indicate how these could be implemented in the mining and decommissioning phases of the project.  Compile a Mitigation and Management Plan to guide the implementation of the mitigation measures, including monitoring criteria to assess the effectiveness of these measures.  Compilation of appropriate rehabilitation plans for the surf-zone and a- concessions, as well as for the offshore concessions 1b, 1c and 4b.

1.2. Approach to the Study All identified marine impacts are summarised, categorised and ranked in appropriate impact assessment tables, to be incorporated in the overall EMPR amendment.

1.2.1 Assumptions, Limitations and Information Gaps As determined by the terms of reference, this study has adopted primarily a ‘desktop’ approach, supplemented by field information collected during the site visit. Consequently, the description of the natural baseline environment in the study area is based largely on the descriptions provided in various EMPRs undertaken for coastal and offshore diamond mining operations. Information had been updated where appropriate. The information for the identification of potential impacts of diamond mining activities on the coastal and marine environment was drawn from various scientific publications, the Generic EMPr for Diamond Mining on the South African West Coast (Lane & Carter 1999) and the Benguela Current Large Marine Ecosystem (BCLME) Thematic Report (Clark et al. 1999) and the assessment of cumulative effects of marine diamond mining activities on the BCLME Region (Penney et al. 2008) and information sourced from the Internet. The sources consulted are listed in the Reference chapter.

Information gaps include:

 information specific to the marine communities of intertidal rocky shores, and nearshore and deep-water reefs;  information specific to the marine communities of intertidal beaches; and  current information on the distribution, population sizes and trends of most cetacean species occurring in South African waters and the project area in particular.

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1.2.2 Impact Assessment Methodology A brief tabulated summary of the impact assessment criteria applied is provided below:

Rating Definition of Rating Intensity – establishes whether the magnitude of the impact is destructive or benign in relation to the sensitivity of the receiving environment Zero to Very Low Negligible change, disturbance or nuisance. The impact affects the environment in such a way that natural functions and processes are not affected. Low Minor (Slight) change, disturbance or nuisance. The impact on the environment is not detectable. Medium Moderate change, disturbance or discomfort. Where the affected environment is altered, but natural functions and processes continue, albeit in a modified way. High Prominent change, disturbance or degradation. Where natural functions or processes are altered to the extent that they will temporarily or permanently cease. Duration – the time frame over which the impact will be experienced Short-term <5 years Medium-term 5 – 15 years Long-term >15 years, but where the impact will eventually cease either because of natural processes or by human intervention Permanent Where mitigation either by natural processes or by human intervention would not occur in such a way or in such time span that the impact can be considered transient Extent – defines the physical extent or spatial scale of the impact Local Extending only as far as the activity, limited to the site and its immediate surroundings Regional Impacts are confined to the region; e.g. coast, basin, etc National Impact is confined to the country as a whole, e.g. South Africa, Namibia, etc. International Impact extends beyond the national scale. Reversibility – defines the potential for recovery to pre-impact conditions Irreversible Where the impact is permanent Partially Reversible Where the impact can be partially reversed Fully Reversible Where the impact can be completely reversed Probability – the likelihood of the impact occurring Where the possibility of the impact to materialise is very low either Improbable because of design or historic experience, i.e. ≤ 30% chance of occurring. Where there is a distinct possibility that the impact would occur, i.e. > 30 Possible to ≤ 60% chance of occurring. Where it is most likely that the impact would occur, i.e. > 60 to ≤ 80% Probable chance of occurring. Where the impact would occur regardless of any prevention measures, i.e. Definite > 80% chance of occurring.

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Rating Definition of Rating Degree of confidence in predictions – in terms of basing the assessment on available information and specialist knowledge Low Less than 35 % sure of impact prediction. Medium Between 35 % and 70 % sure of impact prediction. High Greater than 70 % sure of impact prediction

Using the core criteria above, the consequence of the impact is determined:

Consequence – attempts to evaluate the importance of a particular impact, and in doing so incorporates extent, duration and intensity VERY HIGH Impacts could be EITHER: of high intensity at a regional level and endure in the long term; OR of high intensity at a national level in the medium term; OR of medium intensity at a national level in the long term. HIGH Impacts could be EITHER: of high intensity at a regional level enduring in the medium term; OR of high intensity at a national level in the short term; OR of medium intensity at a national level in the medium term; OR of low intensity at a national level in the long term; OR of high intensity at a local level in the long term; OR of medium intensity at a regional level in the long term. MEDIUM Impacts could be EITHER: of high intensity at a local level and endure in the medium term; OR of medium intensity at a regional level in the medium term; OR of high intensity at a regional level in the short term; OR of medium intensity at a national level in the short term; OR of medium intensity at a local level in the long term; OR of low intensity at a national level in the medium term; OR of low intensity at a regional level in the long term. LOW Impacts could be EITHER of low intensity at a regional level, enduring in the medium term; OR of low intensity at a national level in the short term; OR of high intensity at a local level and endure in the short term; OR of medium intensity at a regional level in the short term; OR of low intensity at a local level in the long term; OR of medium intensity at a local level, enduring in the medium term. VERY LOW Impacts could be EITHER of low intensity at a local level and endure in the medium term; OR of low intensity at a regional level and endure in the short term; OR of low to medium intensity at a local level, enduring in the short term; OR Zero to very low intensity with any combination of extent and duration. UNKNOWN Where it is not possible to determine the significance of an impact.

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The consequence rating is considered together with the probability of occurrence in order to determine the overall significance using the table below.

PROBABILITY IMPROBABLE POSSIBLE PROBABLE DEFINITE

VERY LOW INSIGNIFICANT INSIGNIFICANT VERY LOW VERY LOW LOW VERY LOW VERY LOW LOW LOW MEDIUM LOW LOW MEDIUM MEDIUM HIGH MEDIUM MEDIUM HIGH HIGH CONSEQUENCE VERY HIGH HIGH HIGH VERY HIGH VERY HIGH

Nature of the Impact – describes whether the impact would have a negative, positive or zero effect on the affected environment Positive The impact benefits the environment Negative The impact results in a cost to the environment Neutral The impact has no effect

Type of impacts assessed:

Type of impacts assessed

Direct (Primary) Impacts that result from a direct interaction between a proposed project activity and the receiving environment. Secondary Impacts that follow on from the primary interactions between the project and its environment as a result of subsequent interactions within the environment (e.g. loss of part of a habitat affects the viability of a species population over a wider area). Indirect Impacts that are not a direct result of a proposed project, often produced away from or as a result of a complex impact pathway. Cumulative Additive: impacts that may result from the combined or incremental effects of future activities (i.e. those developments currently in planning and not included as part of the baseline); and In-combination: impacts where individual project-related impacts are likely to affect the same environmental features. For example, a sensitive receptor being affected by both noise and drill cutting during drilling operations could potentially experience a combined effect greater than the individual impacts in isolation.

The relationship between the significance ratings after mitigation and decision-making can be broadly defined as follows:

Significance of residual impacts after Mitigation - considering changes in intensity, extent and duration after mitigation and assuming effective implementation of mitigation measures Very Low; Low Activity could be authorised with little risk of environmental degradation. Medium Activity could be authorised with conditions and inspections. High Activity could be authorised but with strict conditions and high levels of compliance and enforcement. Very High Potential fatal flaw

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2. DESCRIPTION OF THE PROPOSED PROJECT 2.1. Introduction The Mining Works Programme provides details on the location and extent of known and probable diamond bearing gravels occurring within all of PSJV’s five mining right areas (onshore and marine), which extend from the land (above the high water mark) through the surf zone to the various sea concessions (A, B and C) (see Figure 2-1).

Historical and current (1 March 2016 to 28 February 2017) mining areas associated with the marine Mining Rights are indicated in Figure 2-2, while potential future mining areas are presented in Figure 2-3. Although the PSJV has a right to prospect and mine portions of the Orange River, no prospecting or mining activities are being considered for inclusion in this amendment of the EMPR for Mining Right 554MRC.

Similar to the onshore operations, the PSJV outsources the majority of the marine prospecting and mining operations to contractors. The current and potential future prospecting and mining methods are described in the sections below.

Figure 2-1: Schematic cross section of the mining concession areas.

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Figure 2-2: Historical and current (1 March 2016 to 28 February 2017) mining activity.

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Figure 2-3: Historical and future marine mining locations.

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2.2. Marine Prospecting 2.2.1 Geophysical Surveys Geophysical surveys are undertaken to investigate the structure and condition of seabed sediment layers. A number of surveying tools can be considered for use, including:

 Single beam echo sounder.  Bottom profiler.  Multi beam or swat bathymetry (see Figure 2-4).  Side Scan Sonar.  Topas.  Compressed High Intensity Radar Pulse (Chirp).  Boomer.  Plasma sound source (or Sparker).

These surveys can be undertaken from a small ski boat or large ocean going survey vessel, depending primarily on the water depths over which the survey is to be conducted. Shallow water surveys (< 20 m) would be conducted from ski boats, which would return to port daily. Mid- to deep-water surveys (> 20 m) would be undertaken from larger survey vessels that are capable of remaining at sea for several days at a time.

Outputs from these surveys commonly produce detailed images of the seabed, showing topographical features, sediment characterisation (which may subsequently be ground-truthed in order to obtain actual samples from the seabed). Images can also be generated that indicate the sub surface layers below the seabed. From this information set, trap sites (depressions, gulley’s, ridge and other features) are identified for further prospecting or mining.

Figure 2-4: Vessel using multi-beam depth/echo sounders (Source: http://www.gns.cri.nz).

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2.2.2 Sampling Following geophysical survey, samples are collected to gain an understanding of the distribution and grade (number of stones and carets) of diamonds within the gravel horizon. The larger the sample set size, the more reliable the statistical interpretation and confirmation of the resource potential. The larger and more expensive marine operations typically require an extensive data set to verify the economic potential of the deposit.

Various methods are used to ground-truth geophysical survey interpretations, including:

 Coring (e.g. vibrocoring / drop coring): This technique for collecting core samples of underwater sediments. Cores typically comprise of a 10-15 cm diameter samples up to 9 m in length;  Grab samples (see Figure 2-5) or box coring: This technique targets the upper 20 to 30 cm of the seabed surface. The size of sample collected ultimately depends on the grab size. However, replicate samples can be taken at the same location to gather the required volume of sediment for analysis.  Drill sampling (using large-diameter drills): Large vessel-mounted vertical drill tools are capable for working in water depths of approximately 40 m to 180 m. This sampling method can recover sediment to depths of up to 8 m and is the most sophisticated sampling technology available presently.  Bulk sampling: If initial reconnaissance sampling indicates positive results, in-fill bulk sampling may be undertaken. The spacing between the reconnaissance sample locations is reduced by the in-fill sampling, thereby providing a more accurate understanding of the distribution of the prospective deposit. This is sampling is typically undertaken by a large mining vessel where a series of trenches (up to 22 m wide) are excavated across the prospective deposit using a subsea crawler.  Small boat-based diver and mobile pump unit sampling: Prospecting in the surf zone and nearshore areas is essentially undertaken by the boat-based diver operations on trial and error basis. Local knowledge gained from historical mining of coastal structures (e.g. linear features, gullies and ridges) is used for diamond recovery data mapping and projection. The equipment and techniques used by the boat-based diver operations for prospecting are the same as the equipment used for mining. Mobile pump units (e.g. jack-up rigs) could also be used for prospecting in the surf zone and nearshore areas.

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Figure 2-5: Grab sampler (Source: http://www.jochemnet.de/fiu/OCB3043_35.html).

2.3. Marine Mining 2.3.1 Boat- and Shore-Based Diver Assisted Mining Shallow water (or nearshore) mining operations utilise either a vessel to support operations or shore-based support to run the dredge pump and supply air to the divers. These methods are described below. 2.3.1.1 Boat-based diver assisted mining

The diver operations commonly operate in water depths of less than 12 m (A concessions). A boat-based operation typically consists of a 10 - 12 m vessel (see Figure 2-6) with 6 to 8 operational personnel. These vessels are small enough to operate out of Alexander Bay or Port Nolloth. There are currently approximately 40 vessel-based contractors operating in the PSJV shallow water concession areas.

The dredging operations are typically conducted using vessel mounted suction pumps and hoses, which are guided by divers into gullies, potholes and bedrock depressions to retrieve the diamond-bearing gravel. The divers operate via a surface supplied airline, with air generated from a vessel based air compressor.

The gravel is pumped up through the hose gravel pump system to the on-board screening system (trommel). Fine material (<2 mm) and oversized material (>20 mm) discharged from the screening unit washes directly back into the sea. The diamond-bearing gravel is bagged and transported to the onshore processing plants for further processing.

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Figure 2-6: Typical boat used for boat-based diver assisted mining (Source: J. Blood).

2.3.1.2 Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can also be shore-based and locally referred to as “Walpomp” (beach pumping units). There are currently at least 30 shore-based units operating in the surf zone area, each consisting of 2 to 4 divers (working in shifts) and assistance to manage the equipment and bag the recovered gravels.

These mining operations are typically confined to small trap sites. The submerged target gravels are mined by at least two diver-guided suction hoses. The hoses are connected to a shore based tractor that is modified to drive a centripetal pump (see Figure 2-7), which feeds the gravel into a rotary classifier (Trommel). The classifier screens the pumped material and extracts the size fraction of interest (2 to 25 mm). The large size fraction tailings (>25 mm) accumulate around the classifier (being later dispersed during the high tide or mechanically redistributed over the beach), while the fine tailings (<2 mm) are returned directly to the sea as a sediment slurry. The diamond-bearing gravel is bagged and transported to the nearest processing facility for diamond recovery.

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Figure 2-7: “Walpomp” (beach pumping) mining method (Source: J. Blood).

2.3.2 Coffer Dam Mining Beach and surf zone mining using coffer dams occurs from the high-water mark potential up ± 300 m seaward (see Figure 2-8).

This type of mining involves the removal of beach sand overburden with heavy machinery to access target gravels overlying the bedrock. The submerged bedrock below the beach sand is often below mean sea level, which causes flooding of the excavated area during mining operations. Coffer dams are considered to be an efficient mining method for accessing diamondiferous gravels located below the low water mark. The material used to construct these breakwaters typically consists of underlying core of quarried material, which gets progressively coarser towards the outside and is covered by an outer layer of large armour rock. Coffer dams are constantly maintained to restrict the inflow of sea water into the active mining block. When sea water ingresses into the mining area it is pumped back into the sea.

Operations in the beach and surf zone screen the excavated gravels near the mining area and transport the screened gravel to the nearest processing facility.

Coffer dams are typically in operation for up to three years after which a large proportion of the berm is removed, the sea then naturally under wave action remediates the former mined area.

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Figure 2-8: Coffer dam mining operations in Mining Right 554MRC (2017) (Source: Google Earth).

2.3.3 Inter-Tidal Beach Mining Using Mobile Pump Units

An alternative mining technique deployed in the intertidal (surf) zone is a dredging unit mounted on an excavator or on a jack-up rig (see Figure 2-9and Figure 2-10). Both systems make use of a remotely operated articulated dredging arm, which scours/dredges the seafloor.

Areas with generally lower grade, larger volumes of gravel and thicker sand overburden are optimally mined using these methods.

Material is pumped from the seafloor and screened through a classifier, which is normally mounted on-board the mining platform or mobile unit. The screened material is pumped ashore into storage bins, which are transported to the onshore processing plants for diamond recovery.

Figure 2-9: Dredging unit mounted on an excavator (Source: Hannesko).

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Figure 2-10: Jack-up rig / platform (Source: http://www.idexonline.com/FullArticle?id=40041).

2.3.4 Large Vessel Mining

Large vessel mining operations are restricted to Sea Concessions 1C, 1B and 4B, however, vessel mounted dredge pump operations may access the deeper portions of the A concessions. A variety of methods are used to mine these marine diamonds deposits depending on the water depth and topography of the sea floor. These methods are described below. 2.3.4.1 Vessel-based remote dredge pump mining

This mining method is typically used in the A and B Concessions in water depths typically less than 30 m. These vessels are typically smaller than those used in remote airlift and crawler mining described below and can operate out of Port Nolloth and Alexander Bay.

The mining system uses vessel mounted pumps to dredge sediments from the seabed via hoses and a digging head (Figure 2-11). The mining tool consists of a steel pipe fitted with a mining head, which can also be fitted with high pressure water jetting nozzles to agitate the gravel on the seabed. The mining tool is suspended over the side from the aft or along either side of the vessel.

On-board screening and processing is self-contained with final recovery of diamonds taking pace on the vessel. 2.3.4.2 Vessel-based airlift mining

This system is similar in many respects to the dredge pump mining method. However, in the airlift mining method air is pumped down to the digging head, which creates a pressure differential between aerated seawater in the return hose and that of ambient seawater, which in turn draws up the gravel and sediment to the surface. This mining method can operate in greater water depths and is typically used in the B and C Concessions in water depths typically between 30 m and 150 m.

The airlift mining system typically comprises a suspended steel mining tool, suction hoses and on-board air compressors to supply the air chamber at the digging head (see Figure 2-12). The

Pisces Environmental Services (Pty) Ltd 15 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC mining tool itself consists of a steel pipe fitted with a digging head, which is an opening fitted with ”grizzly” bars to allow sized gravel to pass through and prevent blockages in the delivery hose. The digging head can be fitted with high pressure water jetting nozzles, which agitates the gravel on the seabed. The mining tool is suspended from davits (cranes) situated along the side of the vessel. On-board screening and processing is self-contained with final recovery of diamonds taking pace on the vessel.

Figure 2-11: Illustration of remote dredge pump mining (Source: GEMPR, Alexkor).

Figure 2-12: Illustration of airlift mining (Source: BENCO).

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2.3.4.3 Vessel-based remote crawler mining

The mining method uses a remotely operated crawler to mine in the B and C Concessions in water depths between 30 m and 200 m (see Figure 2-13). The mining vessel operates on a 4- point mooring spread with dynamic positioning to assist the crawler mining operations.

Prior to the launching of the seabed crawler, the vessel anchors over a planned mining area. The crawler is then lowered to the seabed by a winch system over the stern of the vessel. The seabed crawler is track-driven and equipped with a dredge pump system, hydraulic power pack and a jet-water system to facilitate the agitation and suction of unconsolidated surficial sediments up to the mining vessel. The seabed crawler can remove seabed sediments to a depth of up to 5 m in a set path within the mine target area.

As the sediment is removed from the seabed it is pumped to the surface for on-board screening and processing. Unwanted material is discarded overboard. The mining and processing operation is fully self-contained on the mining vessel with final recovery of diamonds taking place on the vessel.

Figure 2-13: Illustration of remote crawler mining (Source: De Beers Group).

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3. DESCRIPTION OF THE BASELINE MARINE ENVIRONMENT The descriptions of the physical and biological environments along the South African West Coast focus primarily on the study area between the Orange River mouth and Hondeklipbaai. The purpose of this environmental description is to provide the marine baseline environmental context within which the proposed marine diamond mining would take place. The summaries presented below are primarily based on information gleaned from Lane & Carter (1999) and Penney et al. (2007), and supplemented by updated references where appropriate.

3.1. Geophysical Characteristics 3.1.1 Bathymetry The continental shelf along the West Coast is generally wide and deep, although large variations in both depth and width occur. The shelf maintains a general NNW trend, widening north of Cape Columbine and reaching its widest off the Orange River (180 km) (Figure 3-1). Between Cape Columbine and the Orange River, there is usually a double shelf break, with the distinct inner and outer slopes, separated by a gently sloping ledge. The immediate nearshore area consists mainly of a narrow (about 8 km wide) rugged rocky zone, sloping steeply seawards to a depth of around 80 m. The middle and outer shelf typically lacks relief, sloping gently seawards before reaching the shelf break at a depth of ~300 m.

Figure 3-1: Mining Licence Areas in relation to the regional bathymetry and showing proximity of prominent seabed features.

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Banks on the continental shelf include the Orange Bank (Shelf or Cone), a shallow (160 - 190 m) zone that reaches maximal widths (180 km) offshore of the Orange River, and Child’s Bank, situated ~150 km offshore at about 31°S. Tripp Seamount is a geological feature approximately 250 km to the west-southwest of the western extent of Concession 1C (Figure 3-1), which rises from ~1,000 m to a depth of 150 m.

3.1.2 Coastal and Inner-shelf Geology and Seabed Geomorphology The inner shelf is underlain by Precambrian bedrock (also referred to as Pre-Mesozoic basement), whilst the middle and outer shelf areas are composed of Cretaceous and Tertiary sediments (Dingle 1973; Birch et al. 1976; Rogers 1977; Rogers & Bremner 1991). As a result of erosion on the continental shelf, the unconsolidated surface sediment cover is generally thin, often less than 1 m. Sediments are finer seawards, changing from sand on the inner and outer shelves to muddy sand and sandy mud in deeper water. However, this general pattern has been modified considerably by biological deposition (large areas of shelf sediments contain high levels of calcium carbonate) and localised river input (Figure 3-2). An ~500-km long mud belt (up to 40 km wide, and of 15 m average thickness) is situated over the inner edge of the middle shelf between the Orange River and St Helena Bay (Birch et al. 1976). Further offshore, sediment is dominated by muddy sands, sandy muds, mud and some sand. The continental slope, seaward of the shelf break, has a smooth seafloor, underlain by calcareous ooze.

Figure 3-2: Mining Licence Areas in relation to sediment distribution on the continental shelf (Adapted from Rogers 1977).

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Present day sedimentation is limited to input from the Orange River. As these sediments are generally transported northward, most of the sediment in the project area is considered to be relict deposits by now ephemeral rivers active during wetter climates in the past. The Orange River, when in flood, still contributes largely to the mud belt as suspended sediment is carried southward by poleward flow. In this context, the absence of large sediment bodies on the inner shelf reflects on the paucity of terrigenous sediment being introduced by the few rivers that presently drain the South African West Coast coastal plain.

3.2. Biophysical Characteristics 3.2.1 Wind Patterns Winds are one of the main physical drivers of the nearshore Benguela region, both on an oceanic scale, generating the heavy and consistent south-westerly swells that impact this coast, and locally, contributing to the northward-flowing longshore currents, and being the prime mover of sediments in the terrestrial environment. Physical processes are characterised by the average seasonal wind patterns, and substantial episodic changes in these wind patterns have strong effects on the entire Benguela region.

The prevailing winds in the Benguela region are controlled by the perennial South Atlantic subtropical anticyclone, the eastward moving mid-latitude cyclones south of southern Africa, and the seasonal atmospheric pressure field over the subcontinent. The south Atlantic anticyclone undergoes seasonal variations, being strongest in the austral summer, when it also attains its southernmost extension, lying south west and south of the subcontinent. In winter, the south Atlantic anticyclone weakens and migrates north-westwards.

These seasonal changes result in substantial differences between the typical summer and winter wind patterns in the region, as the southern hemisphere anti-cyclonic high-pressures system, and the associated series of cold fronts, moves northwards in winter, and southwards in summer. The strongest winds occur in summer, during which winds blow 99% of the time Virtually all winds in summer come from the southeast to south-west (Figure 3-3; supplied by CSIR), strongly dominated by southerlies which occur over 40% of the time, averaging 20 - 30 kts and reaching speeds in excess of 100 km/h (60 kts). South-easterlies are almost as common, blowing about one-third of the time, and also averaging 20 - 30 kts. The combination of these southerly/south-easterly winds drives the offshore movements of surface water, and the resultant strong upwelling of nutrient-rich bottom waters, which characterise this region.

Winter remains dominated by southerly to south-easterly winds, but the closer proximity of the winter cold-front systems results in a significant south-westerly to north-westerly component (Figure 3-3). This ‘reversal’ from the summer condition results in cessation of upwelling, movement of warmer mid-Atlantic water shorewards and breakdown of the strong thermoclines which develop in summer. There are more calms in winter, occurring about 3% of the time, and wind speeds generally do not reach the maximum speeds of summer. However, the westerlies winds blow in synchrony with the prevailing south-westerly swell direction, resulting in heavier swell conditions in winter.

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Figure 3-3: VOS Wind Speed vs Wind Direction data for the offshore area 28°-29°S; 15°-16°E (Oranjemund) (Source: Voluntary Observing Ship (VOS) data from the Southern Africa Data Centre for Oceanography (SADCO)).

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3.2.2 Large-Scale Circulation and Coastal Currents The West Coast is strongly influenced by the Benguela Current, with current velocities in continental shelf areas ranging between 10–30 cm/s (Boyd & Oberholster 1994). On its western side, flow is more transient and characterised by large eddies shed from the retroflection of the Agulhas Current. The Benguela current widens northwards to 750 km, with flows being predominantly wind-forced, barotropic and fluctuating between poleward and equatorward flow (Shillington et al. 1990; Nelson & Hutchings 1983). Fluctuation periods of these flows are 3 - 10 days, although the long-term mean current residual is in an approximate northwest (alongshore) direction. Near-bottom shelf flow is mainly poleward (Nelson 1989) with low velocities of typically 5 cm/s.

The major feature of the Benguela Current Coastal is upwelling and the consequent high nutrient supply to surface waters leads to high biological production and large fish stocks. The prevailing longshore, equatorward winds move nearshore surface water northwards and offshore. To balance the displaced water, cold, deeper water wells up inshore. Although the rate and intensity of upwelling fluctuates with seasonal variations in wind patterns, the most intense upwelling tends to occur where the shelf is narrowest and the wind strongest. There are three upwelling centres in the southern Benguela, namely the Namaqua (30°S), Cape Columbine (33°S) and Cape Point (34°S) upwelling cells (Taunton-Clark 1985) (Figure 3-4; bottom left). The project area falls into the Namaqua cell. Upwelling in these cells is seasonal, with maximum upwelling occurring between September and March. An example of one such strong upwelling event in December 1996, followed by relaxation of upwelling and intrusion of warm Agulhas waters from the south, is shown in the satellite images in Figure 3-4.

Figure 3-4: Satellite sea-surface temperature images showing upwelling intensity in the three upwelling cells along the South African west coast on two days in December 1996 (from Lane & Carter 1999). The location of the Concession 3a, 4a and 4b (white polygon) is indicted.

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Where the Agulhas Current passes the southern tip of the Agulhas Bank (Agulhas Retroflection area), it may shed a filament of warm surface water that moves north-westward along the shelf edge towards Cape Point, and Agulhas Rings, which similarly move north-westwards into the South Atlantic Ocean. These rings may extend to the seafloor and west of Cape Town may split, disperse or join with other rings (Figure 3-4). During the process of ring formation, intrusions of cold subantractic water moves into the South Atlantic. The contrast in warm (nutrient-poor) and cold (nutrient-rich) water is thought to be reflected in the presence of cetaceans and large migratory pelgic fish species (Best 2007).

3.2.3 Waves and Tides Most of the west coast of southern Africa is classified as exposed, experiencing strong wave action, rating between 13-17 on the 20 point exposure scale (McLachlan 1980). Much of the coastline is therefore impacted by heavy south-westerly swells generated in the roaring forties, as well as significant sea waves generated locally by the prevailing southerly winds. The peak wave energy periods fall in the range 9.7 – 15.5 seconds.

The wave regime along the southern African west coast shows only moderate seasonal variation in direction, with virtually all swells throughout the year coming from the SW - S direction (Figure 3-5). Winter swells are strongly dominated by those from the SW - SSW, which occur almost 80% of the time, and typically exceed 2 m in height, averaging about 3 m, and often attaining over 5 m. With wind speeds capable of reaching 100 km/h during heavy winter south- westerly storms, winter swell heights can exceed 10 m. Typical seasonal swell-height rose- plots, compiled from Voluntary Observing Ship (VOS) data off Oranjemund, are shown in Figure 3-5 (supplied by CSIR).

Summer swells tend to be smaller on average (~2 m), with a more pronounced southerly component. These southerly swells tend to be wind-induced, with shorter wave periods (~8 seconds), and are generally steeper than swell waves (CSIR 1996). These wind-induced southerly waves are relatively local and, although less powerful, tend to work together with the strong southerly winds of summer to cause the northward-flowing nearshore surface currents, and result in substantial nearshore sediment mobilisation, and northwards transport, by the combined action of currents, wind and waves.

In common with the rest of the southern African coast, tides are semi-diurnal, with a total range of some 1.5 m at spring tide, but only 0.6 m during neap tide periods.

3.2.4 Water South Atlantic Central Water (SACW) comprises the bulk of the seawater in the project area, either in its pure form in the deeper regions, or mixed with previously upwelled water of the same origin on the continental shelf (Nelson & Hutchings 1983). Salinities range between 34.5‰ and 35.5‰ (Shannon 1985).

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Figure 3-5: VOS Wave Height vs Wave Direction data for the offshore area (28°-29°S; 15°-16°E recorded during the period 1 February 1906 and 12 June 2006)) (Source: Voluntary Observing Ship (VOS) data from the Southern African Data Centre for Oceanography (SADCO)).

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Seawater temperatures on the continental shelf typically vary between 6°C and 16°C. Well- developed thermal fronts exist, demarcating the seaward boundary of the upwelled water. Upwelling filaments are characteristic of these offshore thermal fronts, occurring as surface streamers of cold water, typically 50 km wide and extending beyond the normal offshore extent of the upwelling cell. Such fronts typically have a lifespan of a few days to a few weeks, with the filamentous mixing area extending up to 625 km offshore.

The continental shelf waters of the Benguela system are characterised by low oxygen concentrations, especially on the bottom. SACW itself has depressed oxygen concentrations (~80% saturation value), but lower oxygen concentrations (<40% saturation) frequently occur (Bailey et al. 1985; Chapman & Shannon 1985).

Nutrient concentrations of upwelled water attain 20 µm nitrate-nitrogen, 1.5 µm phosphate and 15-20 µm silicate, indicating nutrient enrichment (Chapman & Shannon 1985). This is mediated by nutrient regeneration from biogenic material in the sediments (Bailey et al. 1985). Modification of these peak concentrations depends upon phytoplankton uptake which varies according to phytoplankton biomass and production rate. The range of nutrient concentrations can thus be large but, in general, concentrations are high.

3.2.5 Upwelling & Plankton Production The cold, upwelled water is rich in inorganic nutrients, the major contributors being various forms of nitrates, phosphates and silicates (Chapman & Shannon 1985). During upwelling the comparatively nutrient-poor surface waters are displaced by enriched deep water, supporting substantial seasonal primary phytoplankton production. This, in turn, serves as the basis for a rich food chain up through zooplankton, pelagic baitfish (anchovy, pilchard, round-herring and others), to predatory fish (hake and snoek), mammals (primarily seals and dolphins) and seabirds (jackass penguins, cormorants, pelicans, terns and others). High phytoplankton productivity in the upper layers again depletes the nutrients in these surface waters. This results in a wind-related cycle of plankton production, mortality, sinking of plankton detritus and eventual nutrient re-enrichment occurring below the thermocline as the phytoplankton decays.

3.2.6 Organic Inputs The Benguela upwelling region is an area of particularly high natural productivity, with extremely high seasonal production of phytoplankton and zooplankton. These plankton blooms in turn serve as the basis for a rich food chain up through pelagic baitfish (anchovy, pilchard, round-herring and others), to predatory fish (snoek), mammals (primarily seals and dolphins) and seabirds (jackass penguins, cormorants, pelicans, terns and others). All of these species are subject to natural mortality, and a proportion of the annual production of all these trophic levels, particularly the plankton communities, die naturally and sink to the seabed.

Balanced multispecies ecosystem models have estimated that during the 1990s the Benguela region supported biomasses of 76.9 tons/km2 of phytoplankton and 31.5 tons/km2 of zooplankton alone (Shannon et al. 2003). Thirty six percent of the phytoplankton and 5% of the zooplankton are estimated to be lost to the seabed annually. This natural annual input of millions of tons of organic material onto the seabed off the southern African West Coast has a

Pisces Environmental Services (Pty) Ltd 25 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC substantial effect on the ecosystems of the Benguela region. It provides most of the food requirements of the particulate and filter-feeding benthic communities that inhabit the sandy- muds of this area, and results in the high organic content of the muds in the region. As most of the organic detritus is not directly consumed, it enters the seabed decomposition cycle, resulting in subsequent depletion of oxygen in deeper waters.

An associated phenomenon ubiquitous to the Benguela system are red tides (dinoflagellate and/or ciliate blooms) (see Shannon & Pillar 1985; Pitcher 1998). Also referred to as Harmful Algal Blooms (HABs), these red tides can reach very large proportions, extending over several square kilometres of ocean (Figure 3-6, left). Toxic dinoflagellate species can cause extensive mortalities of fish and shellfish through direct poisoning, while degradation of organic-rich material derived from both toxic and non-toxic blooms results in oxygen depletion of subsurface water (Figure 3-6, right).

Figure 3-6: Red tides can reach very large proportions (Left, Photo: www.e-education.psu.edu) and can lead to mass stranding, or ‘walk-out’ of rock lobsters, such as occurred at Elands Bay in February 2002 (Right, Photo: www.waterencyclopedia.com)

3.2.7 Low Oxygen Events The continental shelf waters of the Benguela system are characterised by low oxygen concentrations with <40% saturation occurring frequently (e.g. Visser 1969; Bailey et al. 1985). The low oxygen concentrations are attributed to nutrient remineralisation in the bottom waters of the system (Chapman & Shannon 1985). The absolute rate of this is dependent upon the net organic material build-up in the sediments, with the carbon rich mud deposits playing an important role. As the mud on the shelf is distributed in discrete patches (see Figure 3-2), there are corresponding preferential areas for the formation of oxygen-poor water. The two main areas of low-oxygen water formation in the southern Benguela region are in the Orange River Bight and St Helena Bay (Chapman & Shannon 1985; Bailey 1991; Shannon & O’Toole 1998; Bailey 1999; Fossing et al. 2000). The spatial distribution of oxygen-poor water in each of the areas is subject to short- and medium-term variability in the volume of hypoxic water that develops. De Decker (1970) showed that the occurrence of low oxygen water off Lambert’s Bay is seasonal, with highest development in summer/autumn. Bailey & Chapman (1991), on the other hand, demonstrated that in the St Helena Bay area daily variability exists as a result of downward flux of oxygen through thermoclines and short-term variations in

Pisces Environmental Services (Pty) Ltd 26 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC upwelling intensity. Subsequent upwelling processes can move this low-oxygen water up onto the inner shelf, and into nearshore waters, often with devastating effects on marine communities.

Periodic low oxygen events in the nearshore region can have catastrophic effects on the marine communities leading to large-scale stranding of rock lobsters, and mass mortalities of marine biota and fish (Newman & Pollock 1974; Matthews & Pitcher 1996; Pitcher 1998; Cockcroft et al. 2000) (see Figure 3-6, right). The development of anoxic conditions as a result of the decomposition of huge amounts of organic matter generated by algal blooms is the main cause for these mortalities and walkouts. The blooms develop over a period of unusually calm wind conditions when sea surface temperatures where high. Algal blooms usually occur during summer-autumn (February to April) but can also develop in winter during the ‘berg’ wind periods, when similar warm windless conditions occur for extended periods.

3.2.8 Turbidity Turbidity is a measure of the degree to which the water loses its transparency due to the presence of suspended particulate matter. Total Suspended Particulate Matter (TSPM) can be divided into Particulate Organic Matter (POM) and Particulate Inorganic Matter (PIM), the ratios between them varying considerably. The POM usually consists of detritus, bacteria, phytoplankton and zooplankton, and serves as a source of food for filter-feeders. Seasonal microphyte production associated with upwelling events will play an important role in determining the concentrations of POM in coastal waters. PIM, on the other hand, is primarily of geological origin consisting of fine sands, silts and clays. Off Namaqualand, the PIM loading in nearshore waters is strongly related to natural inputs from the Orange River (Figure 3-7) or from ‘berg’ wind events (Figure 3-8). ‘Berg’ wind events can potentially contribute the same order of magnitude of sediment input as the annual estimated input of sediment by the Orange River (Shannon & Anderson 1982; Zoutendyk 1992, 1995; Shannon & O’Toole 1998; Lane & Carter 1999). For example, a ‘berg’ wind event in May 1979 described by Shannon and Anderson (1982) was estimated to have transported in the order of 50 million tons of sand out to sea, affecting an area of 20,000 km2 (Figure 3-8).

Concentrations of suspended particulate matter in shallow coastal waters can vary both spatially and temporally, typically ranging from a few mg/ to several tens of mg/ (Bricelj & Malouf 1984; Berg & Newell 1986; Fegley et al. 1992). Field measurements of TSPM and PIM concentrations in the Benguela current system have indicated that outside of major flood events, background concentrations of coastal and continental shelf suspended sediments are generally <12 mg/, showing significant long-shore variation (Zoutendyk 1995). Considerably higher concentrations of PIM have, however, been reported from southern African West Coast waters under stronger wave conditions associated with high tides and storms, or under flood conditions. During storm events, concentrations near the seabed may even reach up to 10,000 mg/ (Miller & Sternberg 1988). In the vicinity of the Orange River mouth, where river outflow strongly influences the turbidity of coastal waters, measured concentrations ranged from 14.3 mg/ at Alexander Bay just south of the mouth (Zoutendyk 1995) to peak values of 7,400 mg/ immediately upstream of the river mouth during the 1988 Orange River flood (Bremner et al. 1990).

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Figure 3-7: Mining Licence areas in relation to a substantial sediment plume emanating from the Orange River Mouth on 11 April 2001 (Satellite image source: eoimages.gsfc.nasa.gov).

The major source of turbidity in the swell-influenced nearshore areas off the West Coast is the redistribution of fine inner shelf sediments by long-period Southern Ocean swells. The current velocities typical of the Benguela (10-30 cm/s) are capable of resuspending and transporting considerable quantities of sediment equatorwards. Under relatively calm wind conditions, however, much of the suspended fraction (silt and clay) that remains in suspension for longer periods becomes entrained in the slow poleward undercurrent (Shillington et al. 1990; Rogers & Bremner 1991).

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Figure 3-8: Aerosol plumes of sand and dust due to a 'berg' wind event: NIMBUS 7 CZCS orbit 2726, 9 May 1979 (690 nm) (Shannon & Anderson 1982).

Superimposed on the suspended fine fraction, is the northward littoral drift of coarser bedload sediments, parallel to the coastline. This northward, nearshore transport is generated by the predominantly south-westerly swell and wind-induced waves. Longshore sediment transport varies considerably in the shore-perpendicular dimension, being substantially higher in the surf zone than at depth, due to high turbulence and convective flows associated with breaking waves, which suspend and mobilise sediment (Smith & Mocke 2002).

On the inner and middle continental shelf, the ambient currents are insufficient to transport coarse sediments typical of those depths, and re-suspension and shoreward movement of these

Pisces Environmental Services (Pty) Ltd 29 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC by wave-induced currents occur primarily under storm conditions (see also Drake et al. 1985; Ward 1985). Data from a Waverider buoy at Port Nolloth have indicated that 2-m waves are capable of re-suspending medium sands (200 µm diameter) at ~10 m depth, whilst 6-m waves achieve this at ~42 m depth. Low-amplitude, long-period waves will, however, penetrate even deeper. Most of the sediment shallower than 90 m can therefore be subject to re-suspension and transport by heavy swells (Lane & Carter 1999).

Mean sediment deposition is naturally higher near the seafloor due to constant re-suspension of coarse and fine PIM by tides and wind-induced waves. Aggregation or flocculation of small particles into larger aggregates occurs as a result of cohesive properties of some fine sediments in saline waters. The combination of re-suspension of seabed sediments by heavy swells, and the faster settling rates of larger inorganic particles, typically causes higher sediment concentrations near the seabed. Significant re-suspension of sediments can also occur up into the water column under stronger wave conditions associated with high tides and storms. Re- suspension can result in dramatic increases in PIM concentrations within a few hours (Sheng et al. 1994). Wind speed and direction have also been found to influence the amount of material re-suspended (Ward 1985).

Although natural turbidity of seawater is a global phenomenon, there has been a worldwide increase of water turbidity and sediment load in coastal areas as a consequence of anthropogenic activities. These include dredging associated with the construction of harbours and coastal installations, beach replenishment, accelerated runoff of eroded soils as a result of deforestation or poor agricultural practices, and discharges from terrestrial, coastal and marine mining operations (Airoldi 2003). Such increase of sediment loads has been recognised as a major threat to marine biodiversity at a global scale (UNEP 1995).

3.3. The Biological Environment Biogeographically, the Mining Licence areas fall into the cold temperate Namaqua Bioregion, which extends from Sylvia Hill, north of Lüderitz in Namibia to Cape Columbine (Emanuel et al. 1992; Lombard et al. 2004) (Figure 3-9). The coastal, wind-induced upwelling characterising the western Cape coastline, is the principle physical process which shapes the marine ecology of the southern Benguela region. The Benguela system is characterised by the presence of cold surface water, high biological productivity, and highly variable physical, chemical and biological conditions. The West Coast is, however, characterized by low marine species richness and low endemicity (Awad et al. 2002).

Communities within marine habitats are largely ubiquitous throughout the southern African West Coast region, being particular only to substrate type (i.e. hard vs. soft bottom), exposure to wave action, or water depth. These biological communities consist of many hundreds of species, often displaying considerable temporal and spatial variability (even at small scales). The mining rights areas extend from the high water mark on the coast to just beyond the 100 m depth contour. The benthic and coastal habitats of South Africa have been mapped by Sink et al. (2011). Those specific to the study area can be broadly grouped into:

• Sandy intertidal and unconsolidated subtidal substrates, and • Intertidal rocky shores and subtidal reefs.

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The biological communities ‘typical’ of these benthic habitats and the overlying water body are described briefly below, focussing both on dominant, commercially important and conspicuous species, as well as potentially threatened or sensitive species, which may be affected by the mining activities. No rare or endangered species have been recorded (Awad et al. 2002).

Figure 3-9: Mining Licence Areas (red polygons) in relation to the South African inshore and offshore bioregions (adapted from Lombard et al. 2004).

3.3.1 Sandy and Unconsolidated Substrate Habitats and Biota The benthic biota of unconsolidated marine sediments constitute invertebrates that live on (epifauna) or burrow within (infauna) the sediments, and are generally divided into macrofauna (animals >1 mm) and meiofauna (<1 mm). 3.3.1.1 Intertidal Sandy Beaches

The coastline from the Orange River mouth to Kleinzee is dominated by rocky shores, interspersed by isolated short stretches of sandy shores. Sandy beaches are one of the most dynamic coastal environments. With the exception of a few beaches in large bay systems (such as St Helena Bay, Saldanha Bay, Table Bay), the beaches along the South African west coast are typically highly exposed. Exposed sandy shores consist of coupled surf zone, beach and dune systems, which together form the active littoral sand transport zone (Short & Hesp 1985). The composition of their faunal communities is largely dependent on the interaction of wave energy, beach slope and sand particle size, which is termed beach morphodynamics. Three morphodynamic beach types are described: dissipative, reflective and intermediate beaches (McLachlan et al. 1993). Generally, dissipative beaches are relatively wide and flat with fine sands and low wave energy. Waves start to break far from the shore in a series of spilling breakers that ‘dissipate’ their energy along a broad surf zone.

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This generates slow swashes with long periods, resulting in less turbulent conditions on the gently sloping beach face. These beaches usually harbour the richest intertidal faunal communities. Reflective beaches in contrast, have high wave energy, and are coarse grained (>500 µm sand) with narrow and steep intertidal beach faces. The relative absence of a surf zone causes the waves to break directly on the shore causing a high turnover of sand. The result is depauperate faunal communities. Intermediate beach conditions exist between these extremes and have a very variable species composition (McLachlan et al. 1993; Jaramillo et al. 1995, Soares 2003). This variability is mainly attributable to the amount and quality of food available. Beaches with a high input of e.g. kelp wrack have a rich and diverse drift-line fauna, which is sparse or absent on beaches lacking a drift-line (Branch & Griffiths 1988). As a result of the combination of typical beach characteristics, and the special adaptations of beach fauna to these, beaches act as filters and energy recyclers in the nearshore environment (Brown & McLachlan 2002).

Numerous methods of classifying beach zonation have been proposed, based either on physical or biological criteria. The general scheme proposed by Branch & Griffiths (1988) is used below (Figure 3-10), supplemented by data from various publications on West Coast sandy beach biota (e.g. Bally 1987; Brown et al. 1989; Soares et al. 1996, 1997; Nel 2001; Nel et al. 2003; Soares 2003; Branch et al. 2010; Harris 2012). The macrofaunal communities of sandy beaches are generally ubiquitous throughout the southern African West Coast region, being particular only to substratum type, wave exposure and/or depth zone. Due to the exposed nature of the coastline in the study area, most beaches are of the intermediate to reflective type. The supralittoral zone is situated above the high water spring (HWS) tide level, and receives water input only from large waves at spring high tides or through sea spray. This zone is characterised by a mixture of air breathing terrestrial and semi-terrestrial fauna, often associated with and feeding on kelp deposited near or on the driftline. Terrestrial species include a diverse array of beetles and arachnids and some oligochaetes, while semi-terrestrial fauna include the oniscid isopod Tylos granulatus, and amphipods of the genus Talorchestia. The intertidal zone or mid-littoral zone has a vertical range of about 2 m. This mid-shore region is characterised by the cirolanid isopods Pontogeloides latipes, Eurydice (longicornis=) kensleyi, and Excirolana natalensis, the polychaetes Scolelepis squamata, Orbinia angrapequensis, Nepthys hombergii and Lumbrineris tetraura, and amphipods of the families Haustoridae and Phoxocephalidae (Figure 3-11). In some areas, juvenile and adult sand mussels Donax serra may also be present in considerable numbers.

The inner turbulent zone extends from the Low Water Spring mark to about -2 m depth. The mysid Gastrosaccus psammodytes (Mysidacea, Crustacea), the ribbon worm Cerebratulus fuscus (Nemertea), the cumacean Cumopsis robusta (Cumacea) and a variety of polychaetes including Scolelepis squamata and Lumbrineris tetraura, are typical of this zone, although they generally extend partially into the midlittoral above. In areas where a suitable swash climate exists, the gastropod Bullia digitalis (Gastropoda, Mollusca) may also be present in considerable numbers, surfing up and down the beach in search of carrion.

The transition zone spans approximately 2 - 5 m depth beyond the inner turbulent zone. Extreme turbulence is experienced in this zone, and as a consequence this zone typically harbours the lowest diversity on sandy beaches. Typical fauna include amphipods such as Cunicus profundus and burrowing polychaetes such as Cirriformia tentaculata and Lumbrineris tetraura.

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Figure 3-10: Schematic representation of the West Coast intertidal beach zonation (adapted from Branch & Branch 1981). Species commonly occurring on the Namaqualand beaches are listed.

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Figure 3-11: Common beach macrofaunal species occurring on exposed West Coast beaches.

The outer turbulent zone extends below 5 m depth, where turbulence is significantly decreased and species diversity is again much higher. In addition to the polychaetes found in the transition zone, other polychaetes in this zone include Pectinaria capensis, and Sabellides ludertizii. The sea pen Virgularia schultzi (Pennatulacea, Cnidaria) is also common as is a host of amphipod species and the three spot swimming crab Ovalipes punctatus (Brachyura, Crustacea). 3.3.1.2 Nearshore and Offshore unconsolidated habitats

Numerous studies have been conducted on southern African West Coast continental shelf benthos, mostly focused on mining, pollution or demersal trawling impacts (Christie & Moldan 1977; Moldan 1978; Jackson & McGibbon 1991; Environmental Evaluation Unit 1996; Parkins & Field 1997; 1998; Pulfrich & Penney 1999; Goosen et al. 2000; Savage et al. 2001; Steffani & Pulfrich 2004, 2007; Steffani 2007a, 2007b; Steffani 2009, 2010; Atkinson et al. 2011; Steffani 2012; Biccard & Clark 2016; Biccard et al. 2016; Mostert et al. 2016). The description below is drawn from recent surveys by Karenyi (unpublished data), De Beers Marine Ltd surveys in 2008 and 2010 (unpublished data), and Mostert et al. (2016) specifically in the Sea Concessions 1B and 1C.

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Three macro-infauna communities have been identified on the inner- (0-30 m depth) and mid- shelf (30-150 m depth, Karenyi unpublished data). The inner-shelf community, which is affected by wave action, is characterised by various mobile predators (e.g. the gastropod Bullia laevissima and polychaete Nereis sp.), sedentary polychaetes and isopods. The mid- shelf community inhabits the mudbelt and is characterised by the mud prawns Callianassa sp. and Calocaris barnardi. A second mid-shelf sandy community occurring in sandy sediments, is characterised by various polychaetes including deposit-feeding Spiophanes soederstromi and Paraprionospio pinnata. Mostert et al. (2016) similarly reported a distinct community inhabiting the very fine sediments characterising Concession 1C, with two naturally highly variable assemblages occurring further inshore in Concession 1B, where sediment types were more variable. Polychaetes, crustaceans and molluscs make up the largest proportion of individuals, biomass and species on the west coast (Figure 3-12), with a total of 57 species being identified in Concessions 1B and 1C. Overall, however, the infaunal benthic communities of the inner shelf exhibit relatively low diversity, being characterised by generalist species that enjoy a widespread regional and global distribution (Steffani et al. 2015). The distribution of species within these communities are inherently patchy reflecting the high natural spatial and temporal variability associated with macro-infauna of unconsolidated sediments (e.g. Kenny et al. 1998; Kendall & Widdicombe 1999; van Dalfsen et al. 2000; Zajac et al. 2000; Parry et al. 2003), with evidence of mass mortalities and substantial recruitments recorded on the South African West Coast (Steffani & Pulfrich 2004). Given the state of our current knowledge of South African macro-infauna it is not possible to determine the threat status or endemicity of macro-infauna species on the West Coast, although such research is currently underway (pers. comm. Ms N. Karenyi, SANBI and NMMU). The marine component of the 2011 National Biodiversity Assessment (Sink et al. 2012), rated portions of the outer continental shelf on the West Coast as ‘vulnerable’ and ‘critically endangered’ (see Figure 3-36), but these areas lie well to the west of the sea concessions in question.

Generally species richness increases from the inner shelf across the mid shelf and is influenced by sediment type (Karenyi unpublished data). The highest total abundance and species diversity was measured in sandy sediments of the mid-shelf. Biomass is highest in the inshore (± 50 g/m2 wet weight) and decreases across the mid-shelf averaging around 30 g/m2 wet weight. This is contrary to Christie (1974) who found that biomass was greatest in the mudbelt at 80 m depth off Lamberts Bay, to the south of the project area, where the sediment characteristics and the impact of environmental stressors (such as low oxygen events) are likely to differ from those occurring further north.

Benthic communities are structured by the complex interplay of a large array of environmental factors. Water depth and sediment grain size are considered the two major factors that determine benthic community structure and distribution on the South African West Coast (Christie 1974, 1976; Steffani & Pulfrich 2004; 2007; Steffani 2007a; 2007b) and elsewhere in the world (e.g. Gray 1981; Ellingsen 2002; Bergen et al. 2001; Post et al. 2006). However, studies have shown that shear bed stress - a measure of the impact of current velocity on sediment – oxygen concentration (Post et al. 2006; Currie et al. 2009; Zettler et al. 2009), productivity (Escaravage et al. 2009), organic carbon and seafloor temperature (Day et al. 1971) may also strongly influence the structure of benthic communities. There are clearly other natural processes operating in the deepwater shelf areas of the West Coast that can

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Figure 3-12: Examples of benthic invertebrate macrofauna found in grab samples from the 2016 PSJV grab campaign: A – Orbinia angrapequensis; B – Amphicteis gunneri; C – Paraphoxus occulatus; D – Harmothoe sp.; E – Pherusa swakopiana; F – Pterygosquilla capensis; G – Callianassa australiensis (Source: Mostert et al. 2016)

over-ride the suitability of sediments in determining benthic community structure, and it is likely that periodic intrusion of low oxygen water masses is a major cause of this variability (Monteiro & van der Plas 2006; Pulfrich et al. 2006). In areas of frequent oxygen deficiency, benthic communities will be characterised either by species able to survive chronic low oxygen conditions, or colonising and fast-growing species able to rapidly recruit into areas that have suffered oxygen depletion. The combination of local, episodic hydrodynamic conditions and patchy settlement of larvae will tend to generate the observed small-scale variability in benthic community structure.

The invertebrate macrofauna are important in the marine benthic environment as they influence major ecological processes (e.g. remineralisation and flux of organic matter deposited on the sea floor, pollutant metabolism, sediment stability) and serve as important food source for commercially valuable fish species and other higher order consumers. As a result of their comparatively limited mobility and permanence over seasons, these animals

Pisces Environmental Services (Pty) Ltd 36 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC provide an indication of historical environmental conditions and provide useful indices with which to measure environmental impacts (Gray 1974; Warwick 1993; Salas et al. 2006).

Also associated with soft-bottom substrates are demersal communities that comprise epifauna and bottom-dwelling vertebrate species, many of which are dependent on the invertebrate benthic macrofauna as a food source. According to Lange (2012), a single epifaunal community occurs between the depths of 100 m and 250 m characterised by the hermit crabs Sympagurus dimorphus and Parapaguris pilosimanus, the prawn Funchalia woodwardi and the sea urchin Brisaster capensis.

3.3.2 Rocky Substrate Habitats and Biota The following general description of the intertidal and subtidal habitats for the West Coast is based on Field et al. (1980), Branch & Branch (1981), Branch & Griffiths (1988) and Field & Griffiths (1991).

3.3.2.1 Intertidal Rocky Shores

Several studies on the west coast of southern Africa have documented the important effects of wave action on the intertidal rocky-shore community. Specifically, wave action enhances filter-feeders by increasing the concentration and turnover of particulate food, leading to an elevation of overall biomass despite a low species diversity (McQuaid & Branch 1985, Bustamante & Branch 1995a, 1996a, Bustamante et al. 1997). Conversely, sheltered shores are diverse with a relatively low biomass, and only in relatively sheltered embayments does drift kelp accumulate and provide a vital support for very high densities of kelp trapping limpets, such as Cymbula granatina that occur exclusively there (Bustamante et al. 1995). In the subtidal, these differences diminish as wave exposure is moderated with depth.

West Coast rocky intertidal shores can be divided into five zones on the basis of their characteristic biological communities: The Littorina, Upper Balanoid, Lower Balanoid, Cochlear/Argenvillei and the Infratidal Zones. These biological zones correspond roughly to zones based on tidal heights (Figure 3-13 and Figure 3-14). Tolerance to the physical stresses associated with life on the intertidal, as well as biological interactions such as herbivory, competition and predation interact to produce these five zones.

The uppermost part of the shore is the supralittoral fringe, which is the part of the shore that is most exposed to air, perhaps having more in common with the terrestrial environment. The supralittoral is characterised by low species diversity, with the tiny periwinkle Afrolittorina knysnaensis, and the red alga Porphyra capensis constituting the most common macroscopic life.

The upper mid-littoral is characterised by the limpet Scutellastra granularis, which is present on all shores. The gastropods Oxystele variegata, Nucella dubia, and Helcion pectunculus are variably present, as are low densities of the barnacles Tetraclita serrata, Octomeris angulosa and Chthalamus dentatus. Flora is best represented by the green algae Ulva spp.

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Figure 3-13: Schematic representation of the West Coast intertidal zonation (adapted from Branch & Branch 1981).

Toward the lower Mid-littoral or Lower Balanoid zone, biological communities are determined by exposure to wave action. On sheltered and moderately exposed shores, a diversity of algae abounds with a variable representation of: green algae – Ulva spp, Codium spp.; brown algae – Splachnidium rugosum; and red algae – Aeodes orbitosa, Mazzaella (=Iridaea) capensis, Gigartina polycarpa (=radula), Sarcothalia (=Gigartina) stiriata, and with increasing wave

Pisces Environmental Services (Pty) Ltd 38 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC exposure Plocamium rigidum and P. cornutum, and Champia lumbricalis. The gastropods Cymbula granatina and Burnupena spp. are also common, as is the reef building polychaete Gunnarea capensis, and the small cushion starfish Patiriella exigua. On more exposed shores, almost all of the primary space can be occupied by the dominant alien invasive mussel Mytilus galloprovincialis. First recorded in 1979 (although it is likely to have arrived in the late 1960’s), it is now the most abundant and widespread invasive marine species spreading along the entire West Coast and parts of the South Coast (Robinson et al. 2005). M. galloprovincialis has partially displaced the local mussels Choromytilus meridionalis and Aulacomya ater (Hockey & Van Erkom Schurink 1992), and competes with several indigenous limpet species (Griffiths et al. 1992; Steffani & Branch 2003a, b). Another alien invasive recorded in the past decade is the acorn barnacle Balanus glandula, which is native to the west coast of North America where it is the most common intertidal barnacle (Simon-Blecher et al. 2008). There is, however, evidence that it has been in South Africa since at least 1992 (Laird & Griffith 2008). At the time of its discovery, the barnacle was recorded from 400 km of coastline from Misty Cliffs near Cape Point to Elands Bay (Laird & Griffith 2008). It has been reported on rocky shores as far north as Lüderitz in Namibia (Pulfrich 2016), and was identified in the mining licence areas during the site visit in July 2017. When present, the barnacle is typically abundant at the mid zones of semi-exposed shores.

Figure 3-14: Typical rocky intertidal zonation on the southern African west coast.

Along the sublittoral fringe, the large kelp-trapping limpet Scutellastra argenvillei dominates forming dense, almost monospecific stands achieving densities of up to 200/m2 (Bustamante et al. 1995). Similarly, C. granatina is the dominant grazer on more sheltered shores, also reaching extremely high densities (Bustamante et al. 1995). On more exposed shores M. galloprovincialis dominates. There is evidence that the arrival of the alien M. galloprovincialis has led to strong competitive interaction with S. argenvillei (Steffani &

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Branch 2003a, 2003b, 2005). The abundance of the mussel changes with wave exposure, and at wave-exposed locations, the mussel can cover almost the entire primary substratum, whereas in semi-exposed situations it is never abundant. As the cover of M. galloprovincialis increases, the abundance and size of S. argenvillei on rock declines and it becomes confined to patches within a matrix of mussel bed. As a result exposed sites, once dominated by dense populations of the limpet, are now largely covered by the alien mussel. Semi-exposed shores do, however, offer a refuge preventing global extinction of the limpet. In addition to the mussel and limpets, there is variable representation of the flora and fauna described for the lower mid- littoral above, as well as the anemone Aulactinia reynaudi, numerous whelk species and the sea urchin Parechinus angulosus. Some of these species extend into the subtidal below.

More recently, the invasion of west coast rocky shores by another mytilid, the hermaphroditic Chilean Semimytilus algosus, was noted (de Greef et al. 2013). It is hypothesized that this species was introduced either by shipping traffic from Namibia (Walvis Bay and Swakopmund) or through the importing of oyster spat from Chile for mariculture purposes. First reported in 2009 from Elands Bay, its distribution spread rapidly to cover 500 km of coastline within a few years (de Greef et al. 2013). Its current range extends from north of the Orange River mouth (pers. obs) to Bloubergstrand in the south. Where present, it occupies the lower intertidal zone completely dominating primary rock space, while M. galloprovincialis dominates higher up the shore. Many shores on the West Coast have thus now been effectively partitioned by the three introduced species, with B. glandula colonizing the upper intertidal, M. galloprovincialis dominating the mid-shore, and now S. algosus smothering the low-shore (de Greef et al. 2013). The shells of S. algosus are, however, typically thin and weak, and have a low attachment strength to the substrate, thereby making the species vulnerable to predators, interference competition, desiccation and the effects of wave action (Zeeman 2016). The competitive ability of S. algosus is strongly related to shore height. Due to intolerance to desiccation, it cannot survive on the high shore, but on the low shore its high recruitment rate offsets the low growth rate, and high mortality rate as a result of wave action and predation.

While most of the rocky shores in the southern mining licence areas will be similar to ‘typical’ shores as described above, those in the northern mining licence areas show evidence of severe sand scouring and periodic sand inundation. Such shores will harbour more sand-tolerant and opportunistic foliose algal genera (e.g. Ulva spp., Grateloupiabelangeri, Nothogenia erinacea) many of which have mechanisms of growth, reproduction and perennation that contribute to their persistence on sand-influenced shores (Daly & Matheison 1977; Airoldi et al. 1995; Anderson et al. 2008). Of the benthic fauna, the sand-tolerant anemone Bunodactis reynaudi, the Cape reef worm Gunnarea gaimardi, and the siphonarid Siphonaria capensis were prevalent, with the anemone in particular occupying much of the intertidal space.

3.3.2.2 Rocky Subtidal Habitat and Kelp Beds

Biological communities of the rocky sublittoral can be broadly grouped into an inshore zone from the sublittoral fringe to a depth of about 10 m dominated by flora, and an offshore zone below 10 m depth dominated by fauna. This shift in communities is not knife-edge, and rather represents a continuum of species distributions, merely with changing abundances.

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From the sublittoral fringe to a depth of between 5 and 10 m, the benthos is largely dominated by algae, in particular two species of kelp. The canopy forming kelp Ecklonia maxima extends seawards to a depth of about 10 m. The smaller Laminaria pallida forms a sub-canopy to a height of about 2 m underneath Ecklonia, but continues its seaward extent to about 30 m depth, although in the northern regions of the west coast, and in the coastal mining licence areas, increasing turbidity limits growth to shallower waters (10-20 m) (Velimirov et al. 1977; Jarman & Carter 1981; Branch 2008). Ecklonia maxima is the dominant species in the south forming extensive beds from west of Cape Agulhas to north of Cape Columbine, but decreasing in abundance northwards. Laminaria becomes the dominant kelp north of Cape Columbine and thus in the project area, extending from Danger Point east of Cape Agulhas to Rocky Point in northern Namibia (Stegenga et al. 1997; Rand 2006).

Kelp beds absorb and dissipate much of the typically high wave energy reaching the shore, thereby providing important partially-sheltered habitats for a high diversity of marine flora and fauna, resulting in diverse and typical kelp-forest communities being established (Figure 3-15). Through a combination of shelter and provision of food, kelp beds support recruitment and complex trophic food webs of numerous species, including commercially important rock lobster stocks (Branch 2008).

Figure 3-15: The canopy-forming kelp Ecklonia maxima provides an important habitat for a diversity of marine biota (Photos: West Coast Abalone).

Growing beneath the kelp canopy, and epiphytically on the kelps themselves, are a diversity of understorey algae, which provide both food and shelter for predators, grazers and filter- feeders associated with the kelp bed ecosystem. Representative under-storey algae include Botryocarpa prolifera, Neuroglossum binderianum, Botryoglossum platycarpum, Hymenena venosa and Rhodymenia (=Epymenia) obtusa, various coralline algae, as well as subtidal extensions of some algae occurring primarily in the intertidal zones (Bolton 1986). Epiphytic species include Polysiphonia virgata, Gelidium vittatum (=Suhria vittata) and Carpoblepharis flaccida. In particular, encrusting coralline algae are important in the under-storey flora as they are known as settlement attractors for a diversity of invertebrate species. The presence of coralline crusts is thought to be a key factor in supporting a rich shallow-water community by providing substrate, refuge, and food to a wide variety of infaunal and epifaunal invertebrates (Chenelot et al. 2008).

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The sublittoral invertebrate fauna is dominated by suspension and filter-feeders, such as the mussels Aulacomya ater and Choromytilus meriodonalis, and the Cape reef worm Gunnarea gaimardi, and a variety of sponges and sea cucumbers. Grazers are less common, with most herbivory being restricted to grazing of juvenile algae or debris-feeding on detached macrophytes. The dominant herbivore is the sea urchin Parechinus angulosus, with lesser grazing pressure from limpets, the isopod Paridotea reticulata and the amphipod Ampithoe humeralis. The abalone Haliotis midae, an important commercial species present in kelp beds south of Cape Columbine is naturally absent north of Cape Columbine, although attempts at ranching this species along the Namaqualand coast are currently underway. Key predators in the sub-littoral include the commercially important West Coast rock lobster Jasus lalandii and the octopus Octopus vulgaris. The rock lobster acts as a keystone species as it influences community structure via predation on a wide range of benthic organisms (Mayfield et al. 2000). Relatively abundant rock lobsters can lead to a reduction in density, or even elimination, of black mussel Choromytilus meriodonalis, the preferred prey of the species, and alter the size structure of populations of ribbed mussels Aulacomya ater, reducing the proportion of selected size-classes (Griffiths & Seiderer 1980). Their role as predator can thus reshape benthic communities, resulting in large reductions in taxa such as black mussels, urchins, whelks and barnacles, and in the dominance of algae (Barkai & Branch 1988; Mayfield 1998).

Of lesser importance as predators, although numerically significant, are various starfish, feather and brittle stars, and gastropods, including the whelks Nucella spp. and Burnupena spp. Fish species commonly found in kelp beds off the West Coast include hottentot Pachymetopon blochii, two tone finger fin Chirodactylus brachydactylus, red fingers Cheilodactylus fasciatus, galjoen Dichistius capensis, rock suckers Chorisochismus dentex and the catshark Haploblepharus pictus (Branch et al. 2010).

There is substantial spatial and temporal variability in the density and biomass of kelp beds, as storms can remove large numbers of plants and recruitment appears to be stochastic and unpredictable (Levitt et al. 2002; Rothman et al. 2006). Some kelp beds are dense, whilst others are less so due to differences in seabed topography, and the presence or absence of sand and grazers.

3.3.2.3 Deep-water coral communities

There has been increasing interest in deep-water corals in recent years because of their likely sensitivity to disturbance and their long generation times. These benthic filter-feeders generally occur at depths below 150 m with some species being recorded from as deep as 3,000 m. Some species form reefs while others are smaller and remain solitary. Corals add structural complexity to otherwise uniform seabed habitats thereby creating areas of high biological diversity (Breeze et al. 1997; MacIssac et al. 2001) (Figure 3-16). Deep water corals establish themselves below the thermocline where there is a continuous and regular supply of concentrated particulate organic matter, caused by the flow of a relatively strong current over special topographical formations which cause eddies to form. Nutrient seepage from the substratum might also promote a location for settlement (Hovland et al. 2002). In the productive Benguela region, substantial areas on the shelf should thus potentially be capable of supporting rich, cold water, benthic, filter-feeding communities.

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Two geological features of note in the vicinity of Sea Concession 1C are Child’s Bank, situated ~150 km offshore at about 31°S and ~200 km south-southwest of the concession area (Sea Concession 4B), and Tripp Seamount situated ~250 km offshore at about 29°40’S and ~250 km to the west southwest of the concession area (Sea Concession 1C). Child’s Bank was described by Dingel et al. (1987) to be a carbonate mound (bioherm). Composed of sediments and the calcareous deposits from an accumulation of carbonate skeletons of sessile organisms (e.g. cold-water coral, foraminifera or marl), such features typically have topographic relief, forming isolated seabed knolls in otherwise low profile homogenous seabed habitats (Kopaska- Merkel & Haywick 2001; Kenyon et al. 2003, Wheeler et al. 2005, Colman et al. 2005). Features such as banks, knolls and seamounts (referred to collectively here as “seamounts”), which protrude into the water column, are subject to, and interact with, the water currents surrounding them. The effects of such seabed features on the surrounding water masses can include the up-welling of relatively cool, nutrient-rich water into nutrient-poor surface water thereby resulting in higher productivity (Clark et al. 1999), which can in turn strongly influences the distribution of organisms on and around seamounts. Evidence of enrichment of bottom-associated communities and high abundances of demersal fishes has been regularly reported over such seabed features.

Figure 3-16: Seamounts are characterised by a diversity of deep-water corals that add structural complexity to seabed habitats and offer refugia for a variety of invertebrates and fish (Photos: www.dfo-mpo.gc.ca/science/Publications/article/2007/21-05-2007-eng.htm, Ifremer & AWI 2003).

The enhanced fluxes of detritus and plankton that develop in response to the complex current regimes lead to the development of detritivore-based food-webs, which in turn lead to the presence of seamount scavengers and predators. Seamounts provide an important habitat for commercial deepwater fish stocks such as orange roughy, oreos, alfonsino and Patagonian toothfish, which aggregate around these features for either spawning or feeding (Koslow 1996).

Such complex benthic ecosystems in turn enhance foraging opportunities for many other predators, serving as mid-ocean focal points for a variety of pelagic species with large ranges (turtles, tunas and billfish, pelagic sharks, cetaceans and pelagic seabirds) that may migrate large distances in search of food or may only congregate on seamounts at certain times (Hui

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1985; Haney et al. 1995). Seamounts thus serve as feeding grounds, spawning and nursery grounds and possibly navigational markers for a large number of species (SPRFMA 2007).

Enhanced currents, steep slopes and volcanic rocky substrata, in combination with locally generated detritus, favour the development of suspension feeders in the benthic communities characterising seamounts (Rogers 1994). Deep- and cold-water corals (including stony corals, black corals and soft corals) (Figure 3-17, left) are a prominent component of the suspension- feeding fauna of many seamounts, accompanied by barnacles, bryozoans, polychaetes, molluscs, sponges, sea squirts, basket stars, brittle stars and crinoids (reviewed in Rogers 2004). There is also associated mobile benthic fauna that includes echinoderms (sea urchins and sea cucumbers) and crustaceans (crabs and lobsters) (reviewed by Rogers 1994; Kenyon et al. 2003). Some of the smaller cnidarians species remain solitary while others form reefs thereby adding structural complexity to otherwise uniform seabed habitats. The coral frameworks offer refugia for a great variety of invertebrates and fish (including commercially important species) within, or in association with, the living and dead coral framework (Figure 3-17, right) thereby creating spatially fragmented areas of high biological diversity. Compared to the surrounding deep-sea environment, seamounts typically form biological hotspots with a distinct, abundant and diverse fauna, many species of which remain unidentified. Consequently, the fauna of seamounts is usually highly unique and may have a limited distribution restricted to a single geographic region, a seamount chain or even a single seamount location (Rogers et al. 2008). Levels of endemism on seamounts are also relatively high compared to the deep sea. As a result of conservative life histories (i.e. very slow growing, slow to mature, high longevity, low levels of recruitment) and sensitivity to changes in environmental conditions, such biological communities have been identified as Vulnerable Marine Ecosystems (VMEs). They are recognised as being particularly sensitive to anthropogenic disturbance (primarily deep-water trawl fisheries and mining), and once damaged are very slow to recover, or may never recover (FAO 2008).

Figure 3-17: Gorgonians and bryozoans communities recorded on deep-water reefs (100-120 m) off the southern African West Coast (Photos: De Beers Marine).

It is not always the case that seamount habitats are VMEs, as some seamounts may not host communities of fragile animals or be associated with high levels of endemism. South Africa’s seamounts and their associated benthic communities have not been extensively sampled by

Pisces Environmental Services (Pty) Ltd 44 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC either geologists or biologists (Sink & Samaai 2009). Deep water corals are known from Child’s Bank (see below) as well as the iBhubezi Reef to the south-east of Child’s Bank. Furthermore, evidence from video footage taken on hard-substrate habitats in 100 - 120 m depth off South Africa (De Beers Marine, unpublished data) (Figure 3-17) suggest that vulnerable communities including gorgonians, octocorals and reef-building sponges do occur on the continental shelf, and similar communities may thus occur in Sea Concession 1C.

3.3.3 The Water Body

3.3.3.1 Demersal Fish Species

Demersal fish are those species that live and feed on or near the seabed. As many as 110 species of bony and cartilaginous fish have been identified in the demersal communities on the continental shelf of the West Coast (Roel 1987). Changes in fish communities occur with increasing depth (Roel 1987; Smale et al. 1993; Macpherson & Gordoa 1992; Bianchi et al. 2001; Atkinson 2009), with the most substantial change in species composition occurring in the shelf break region between 300 m and 400 m depth (Roel 1987; Atkinson 2009) and well offshore of Concession 1C. The shelf community (<380 m) is dominated by the Cape hake M. capensis, and includes jacopever Helicolenus dactylopterus, Izak catshark Holohalaelurus regain, soupfin shark Galeorhinus galeus and whitespotted houndshark Mustelus palumbes. The more diverse deeper water community is dominated by the deepwater hake Merluccius paradoxus, monkfish Lophius vomerinus, kingklip Genypterus capensis, bronze whiptail Lucigadus ori and hairy conger Bassanago albescens and various squalid shark species. There is some degree of species overlap between the depth zones.

Roel (1987) showed seasonal variations in the distribution ranges shelf communities, with species such as the pelagic goby Sufflogobius bibarbatus, and West Coast sole Austroglossus microlepis occurring in shallow water north of Cape Point during summer only. The deep-sea community was found to be homogenous both spatially and temporally. In a more recent study, however, Atkinson (2009) identified two long-term community shifts in demersal fish communities; the first (early to mid-1990s) being associated with an overall increase in density of many species, whilst many species decreased in density during the second shift (mid-2000s). These community shifts correspond temporally with regime shifts detected in environmental forcing variables (Sea Surface Temperatures and upwelling anomalies) (Howard et al. 2007) and with the eastward shifts observed in small pelagic fish species and rock lobster populations (Coetzee et al. 2008, Cockcroft et al. 2008).

The diversity and distribution of demersal cartilagenous fishes on the West Coast is discussed by Compagno et al. (1991). The species likely to occur in the mining licence areas, and their approximate depth range, are listed in Table 3-1.

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Table 3-1: Demersal cartilaginous species found on the continental shelf along the West Coast, with approximate depth range at which the species occurs (Compagno et al. 1991).

Common Name Scientific name Depth Range Six gill cowshark Hexanchus griseus 150-600 Bramble shark Echinorhinus brucus 55-285 Spotted spiny dogfish Squalus acanthias 100-400 Shortnose spiny dogfish Squalus megalops 75-460 Shortspine spiny dogfish Squalus mitsukurii 150-600 Sixgill sawshark Pliotrema warreni 60-500 Tigar catshark Halaelurus natalensis 50-100 Izak catshark Holohalaelurus regani 100-500 Yellowspotted catshark Scyliorhinus capensis 150-500 Soupfin shark/Vaalhaai Galeorhinus galeus <10-300 Houndshark Mustelus mustelus <100 Little guitarfish Rhinobatos annulatus >100 Atlantic electric ray Torpedo nobiliana 120-450 Thorny skate Raja radiata 50-600 Slime skate Raja pullopunctatus 15-460 Rough-belly skate Raja springeri 85-500 Yellowspot skate Raja wallacei 70-500 Biscuit skate Raja clavata 25-500 Bigthorn skate Raja confundens 100-800 Spearnose skate Raja alba 75-260 St Joseph Callorhinchus capensis 30-380

Plankton

Plankton is particularly abundant in the shelf waters off the West Coast, being associated with the upwelling characteristic of the area. Plankton range from single-celled bacteria to jellyfish of 2-m diameter, and include bacterio-plankton, phytoplankton, zooplankton, and ichthyoplankton (Figure 3-18).

Phytoplankton are the principle primary producers with mean productivity ranging from 2.5 - 3.5 g C/m2/day for the midshelf region and decreasing to 1 g C/m2/day inshore of 130 m (Shannon & Field 1985; Mitchell-Innes & Walker 1991; Walker & Peterson 1991). The phytoplankton is dominated by large-celled organisms, which are adapted to the turbulent sea conditions. The most common diatom genera are Chaetoceros, Nitschia, Thalassiosira, Skeletonema, Rhizosolenia, Coscinodiscus and Asterionella (Shannon & Pillar 1985). Diatom blooms occur after upwelling events, whereas dinoflagellates (e.g. Prorocentrum, Ceratium and Peridinium) are more common in blooms that occur during quiescent periods, since they can grow rapidly at low nutrient concentrations. In the surf zone, diatoms and dinoflagellates are nearly equally important members of the phytoplankton, and some silicoflagellates are also present.

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3.3.3.2 Pelagic Communities

In contrast to demersal and benthic biota which are associated with the seabed, pelagic species live and feed in the open water column. The pelagic communities are typically divided into plankton and fish, and their main predators, marine mammals (seals, dolphins and whales), seabirds and turtles.

Figure 3-18: Phytoplankton (left, photo: hymagazine.com) and zooplankton (right, photo: mysciencebox.org) is associated with upwelling cells.

Red-tides are ubiquitous features of the Benguela system (see Shannon & Pillar 1986). The most common species associated with red tides (dinoflagellate and/or ciliate blooms) are Noctiluca scintillans, Gonyaulax tamarensis, G. polygramma and the ciliate Mesodinium rubrum. Gonyaulax and Mesodinium have been linked with toxic red tides. Most of these red- tide events occur quite close inshore although Hutchings et al. (1983) have recorded red-tides 30 km offshore. They are unlikely to occur in the offshore regions of the mining right area (i.e. Sea Concession 1C).

The mesozooplankton (200 µm) is dominated by copepods, which are overall the most dominant and diverse group in southern African zooplankton. Important species are Centropages brachiatus, Calanoides carinatus, Metridia lucens, Nannocalanus minor, Clausocalanus arcuicornis, Paracalanus parvus, P. crassirostris and Ctenocalanus vanus. All of the above species typically occur in the phytoplankton rich upper mixed layer of the water column, with the exception of M. lucens which undertakes considerable vertical migration.

The macrozooplankton (1,600 µm) are dominated by euphausiids of which 18 species occur in the area. The dominant species occurring in the nearshore are Euphausia lucens and Nyctiphanes capensis, although neither species appears to survive well in waters seaward of oceanic fronts over the continental shelf (Pillar et al. 1991).

Standing stock estimates of mesozooplankton for the southern Benguela area range from 0.2 - 2.0 g C/m2, with maximum values recorded during upwelling periods. Macrozooplankton biomass ranges from 0.1-1.0 g C/m2, with production increasing north of Cape Columbine (Pillar 1986). Although it shows no appreciable onshore-offshore gradients, standing stock is highest over the shelf, with accumulation of some mobile zooplanktors (euphausiids) known to occur at oceanographic fronts. Beyond the continental slope biomass decreases markedly.

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Zooplankton biomass varies with phytoplankton abundance and, accordingly, seasonal minima will exist during non-upwelling periods when primary production is lower (Brown 1984; Brown & Henry 1985), and during winter when predation by recruiting anchovy is high. More intense variation will occur in relation to the upwelling cycle; newly upwelled water supporting low zooplankton biomass due to paucity of food, whilst high biomasses develop in aged upwelled water subsequent to significant development of phytoplankton. Irregular pulsing of the upwelling system, combined with seasonal recruitment of pelagic fish species into West Coast shelf waters during winter, thus results in a highly variable and dynamic balance between plankton replenishment and food availability for pelagic fish species.

The mining Licence Areas lie within the influence of the Namaqua upwelling cell, and seasonally high phytoplankton abundance can be expected in the southern licence areas, providing favourable feeding conditions for micro-, meso- and macrozooplankton, and for ichthyoplankton. However, in the Orange River Cone area immediately to the north of the upwelling cell, high turbulence and deep mixing in the water column result in diminished phytoplankton biomass and consequently the area is considered to be an environmental barrier to the transport of ichthyoplankton from the southern to the northern Benguela upwelling ecosystems. Important pelagic fish species, including anchovy, redeye round herring, horse mackerel and shallow-water hake, are reported as spawning on either side of the Orange River Cone area, but not within it (Figure 3-19). Phytoplankton, zooplankton and ichthyoplankton abundances in the northern mining licence areas (1A, 1B, 1C, 2A) are thus expected to be comparatively low.

Cephalopods

The major cephalopod resource in the southern Benguela are sepiods/cuttlefish (Lipinski 1992; Augustyn et al. 1995). Most of the cephalopod resource is distributed on the mid-shelf with Sepia australis being most abundant at depths between 60-190 m, whereas S. hieronis densities were higher at depths between 110-250 m. Rossia enigmatica occurs more commonly on the edge of the shelf to depths of 500 m. Biomass of these species was generally higher in the summer than in winter.

Cuttlefish are largely epi-benthic and occur on mud and fine sediments in association with their major prey item; mantis shrimps (Augustyn et al. 1995). They form an important food item for demersal fish.

Pelagic Fish

The structure of the nearshore and surf zone fish community varies greatly with the degree of wave exposure. Species richness and abundance is generally high in sheltered and semi- exposed areas but typically very low off the more exposed beaches (Clark 1997a, 1997b). The surf zone and outer turbulent zone habitats of sandy beaches are considered to be important nursery habitats for marine fishes (Modde 1980; Lasiak 1981; Kinoshita & Fujita 1988; Clark et al. 1994). However, the composition and abundance of the individual assemblages seems to be heavily dependent on wave exposure (Blaber & Blaber 1980, Potter et al. 1990, Clark 1997a, 1997b). Surf zone fish communities off the South African West Coast have relatively high

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Figure 3-19: Mining Licence Areas (red polygons) in relation to major spawning areas in the southern Benguela region (adapted from Cruikshank 1990).

Pisces Environmental Services (Pty) Ltd 49 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC biomass, but low species diversity. Typical surf zone fish include harders (Liza richardsonii), white stumpnose (Rhabdosargus globiceps) (Figure 3-20), Cape sole (Heteromycteris capensis), Cape gurnard (Chelidonichthys capensis), False Bay klipfish (Clinus latipennis), sandsharks (Rhinobatos annulatus), eagle ray (Myliobatis aquila), and smooth-hound (Mustelus mustelus) (Clark 1997b).

Fish species commonly found in kelp beds off the West Coast include hottentot Pachymetopon blochii (Figure 3-21, left), twotone fingerfin Chirodactylus brachydactylus (Figure 3-21, right), red fingers Cheilodactylus fasciatus, galjoen Dichistius capensis, rock suckers Chorisochismus dentex, maned blennies Scartella emarginata and the catshark Haploblepharus pictus (Sauer et al. 1997; Brouwer et al. 1997; Branch et al. 2010).

Figure 3-20: Common surf zone fish include the harder (left, photo: aquariophil.org) and the white stumpnose (right, photo: easterncapescubadiving.co.za).

Figure 3-21: Common fish found in kelp beds include the Hottentot fish (left, photo: commons. wikimedia.org) and the twotone fingerfin (right, photo: www.parrphotographic.com).

Small pelagic species occurring beyond the surfzone and generally within the 200 m contour include the sardine/pilchard (Sadinops ocellatus) (Figure 3-22, left), anchovy (Engraulis capensis), chub mackerel (Scomber japonicus), horse mackerel (Trachurus capensis) (Figure 3-22, right) and round herring (Etrumeus whiteheadi). These species typically occur in mixed shoals of various sizes (Crawford et al. 1987), and exhibit similar life history patterns involving seasonal migrations between the west and south coasts. The spawning areas of the major pelagic species are distributed on the continental shelf and along the shelf edge from south of

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St Helena Bay to Mossel Bay on the South Coast (Shannon & Pillar 1986). They spawn downstream of major upwelling centres in spring and summer, and their eggs and larvae are subsequently carried around Cape Point and up the coast in northward flowing surface waters.

At the start of winter every year, juveniles of most small pelagic shoaling species recruit into coastal waters in large numbers between the Orange River and Cape Columbine. They recruit in the pelagic stage, across broad stretches of the shelf, to utilise the shallow shelf region as nursery grounds before gradually moving southwards in the inshore southerly flowing surface current, towards the major spawning grounds east of Cape Point. Recruitment success relies on the interaction of oceanographic events, and is thus subject to spatial and temporal variability. Consequently, the abundance of adults and juveniles of these small, short-lived (1-3 years) pelagic fish is highly variable both within and between species.

Figure 3-22: Cape fur seal preying on a shoal of pilchards (left). School of horse mackerel (right) (photos: www.underwatervideo.co.za; www.delivery.superstock.com).

Two species that migrate along the West Coast following the shoals of anchovy and pilchards are snoek Thyrsites atun and chub mackerel Scomber japonicas. Their appearance along the West and South-West coasts are highly seasonal. Snoek migrating along the southern African West Coast reach the area between St Helena Bay and the Cape Peninsula between May and August. They spawn in these waters between July and October before moving offshore and commencing their return northward migration (Payne & Crawford 1989). They are voracious predators occurring throughout the water column, feeding on both demersal and pelagic invertebrates and fish. Chub mackerel similarly migrate along the southern African West Coast reaching South-Western Cape waters between April and August. They move inshore in June and July to spawn before starting the return northwards offshore migration later in the year. Their abundance and seasonal migrations are thought to be related to the availability of their shoaling prey species (Payne & Crawford 1989).

Large pelagic species include tunas, billfish and pelagic sharks, which migrate throughout the southern oceans, between surface and deep waters (>300 m) and have a highly seasonal abundance in the Benguela. Species occurring off western southern Africa include the albacore/longfin tuna Thunnus alalunga (Figure 3-23, right), yellowfin T. albacares, bigeye T. obesus, and skipjack Katsuwonus pelamis tunas, as well as the Atlantic blue marlin Makaira nigricans (Figure 3-23, left), the white marlin Tetrapturus albidus and the broadbill swordfish

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Xiphias gladius (Payne & Crawford 1989). The distributions of these species is dependent on food availability in the mixed boundary layer between the Benguela and warm central Atlantic waters. Concentrations of large pelagic species are also known to occur associated with underwater feature such as canyons and seamounts as well as meteorologically induced oceanic fronts (Penney et al. 1992).

A number of species of pelagic sharks are also known to occur on the West Coast, including blue Prionace glauca, short-fin mako Isurus oxyrinchus and oceanic whitetip sharks Carcharhinus longimanus. Occurring throughout the world in warm temperate waters, these species are usually found further offshore on the West Coast. Great whites Carcharodon carcharias may also be encountered in coastal and offshore areas. This species is a significant apex predator along the southern African coast, particularly in the vicinity of the seal colonies. Although not necessarily threatened with extinction, great whites are listed in Appendix II (species in which trade must be controlled in order to avoid utilization incompatible with their survival) of CITES (Convention on International Trade in Endangered Species) and is described as “vulnerable” in the International Union for Conservation of Nature (IUCN) Red listing. In response to global declines in abundance, white sharks were legislatively protected in South Africa in 1991.

Figure 3-23: Large migratory pelagic fish such as blue marlin (left) and longfin tuna (right) occur in offshore waters (photos: www.samathatours.com; www.osfimages.com).

Many of the large migratory pelagic species are considered threatened by the IUCN, primarily due to overfishing (Table3-2). Tuna and swordfish are targeted by high seas fishing fleets and illegal overfishing has severely damaged the stocks of many of these species. Similarly, pelagic sharks, are either caught as bycatch in the pelagic tuna longline fisheries, or are specifically targeted for their fins, where the fins are removed and the remainder of the body discarded.

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Table 3-2: Some of the more important large migratory pelagic fish likely to occur in the offshore regions of the South Coast.

Common Name Species IUCN Conservation Status Tunas Southern Bluefin Tuna Thunnus maccoyii Critically Endangered Bigeye Tuna Thunnus obesus Vulnerable Longfin Tuna/Albacore Thunnus alalunga Near Threatened Yellowfin Tuna Thunnus albacares Near Threatened Frigate Tuna Auxis thazard Least concern Skipjack Tuna Katsuwonus pelamis Least concern Billfish Blue Marlin Makaira nigricans Vulnerable Sailfish Istiophorus platypterus Least concern Swordfish Xiphias gladius Least concern Black Marlin Istiompax indica Data deficient Pelagic Sharks Pelagic Thresher Shark Alopias pelagicus Vulnerable Common Thresher Shark Alopias vulpinus Vulnerable Great White Shark Carcharodon carcharias Vulnerable Shortfin Mako Isurus oxyrinchus Vulnerable Longfin Mako Isurus paucus Vulnerable Blue Shark Prionace glauca Near Threatened Oceanic Whitetip Shark Carcharhinus longimanus Vulnerable

Turtles

Three species of turtle occur along the West Coast, namely the Leatherback (Dermochelys coriacea) (Figure 3-24, left), and occasionally the Loggerhead (Caretta caretta) (Figure 3-24, right) and the Green (Chelonia mydas) turtle. Loggerhead and Green turtles are expected to occur only as occasional visitors along the West Coast.

The Leatherback is the only turtle likely to be encountered in the offshore waters of west South Africa. The Benguela ecosystem, especially the northern Benguela where jelly fish numbers are high, is increasingly being recognized as a potentially important feeding area for leatherback turtles from several globally significant nesting populations in the south Atlantic (Gabon, Brazil) and south east Indian Ocean (South Africa) (Lambardi et al. 2008, Elwen & Leeney 2011). Leatherback turtles from the east South Africa population have been satellite tracked swimming around the west coast of South Africa and remaining in the warmer waters west of the Benguela ecosystem (Lambardi et al. 2008) (Figure 3-25).

Leatherback turtles inhabit deeper waters and are considered a pelagic species, travelling the ocean currents in search of their prey (primarily jellyfish). While hunting they may dive to over 600 m and remain submerged for up to 54 minutes (Hays et al. 2004). Their abundance in the study area is unknown but expected to be low. Leatherbacks feed on jellyfish and are known to have mistaken plastic marine debris for their natural food. Ingesting this can

Pisces Environmental Services (Pty) Ltd 53 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC obstruct the gut, lead to absorption of toxins and reduce the absorption of nutrients from their real food. Leatherback Turtles are listed as “Critically Endangered” worldwide by the IUCN and are in the highest categories in terms of need for conservation in CITES (Convention on International Trade in Endangered Species), and Convention on Migratory Species. Loggerhead and green turtles are listed as “Endangered”. As a signatory of the Convention on Migratory Species, South Africa has endorsed and signed an International Memorandum of Understanding specific to the conservation of marine turtles. South Africa is thus committed to conserve these species at an international level.

Figure 3-24: Leatherback (left) and loggerhead turtles (right) occur along the West Coast of Southern Africa (Photos: Ketos Ecology 2009; www.aquaworld-crete.com).

Figure 3-25: The post-nesting distribution of nine satellite tagged leatherback females (1996 – 2006; Oceans and Coast, unpublished data). The location of the Mining Licence Areas is indicated.

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Seabirds

Large numbers of pelagic seabirds exploit the pelagic fish stocks of the Benguela system. Of the 49 species of seabirds that occur in the Benguela region, 14 are defined as resident, 10 are visitors from the northern hemisphere and 25 are migrants from the southern Ocean. The 18 species classified as being common in the southern Benguela are listed in Table 3-3. The area between Cape Point and the Orange River supports 38% and 33% of the overall population of pelagic seabirds in winter and summer, respectively. Most of the species in the region reach highest densities offshore of the shelf break (200 – 500 m depth) with highest population levels during their non-breeding season (winter). Pintado petrels and Prion spp. show the most marked variation here.

14 species of seabirds breed in southern Africa; Cape Gannet (Figure 3-26, left), African Penguin (Figure 3-26, right), four species of Cormorant, White Pelican, three Gull and four Tern species (Table 3-4). The breeding areas are distributed around the coast with islands being especially important. The number of successfully breeding birds at the particular breeding sites varies with food abundance. Most of the breeding seabird species forage at sea with most birds being found relatively close inshore (10-30 km). Cape Gannets, however, are known to forage up to 140 km offshore (Dundee 2006; Ludynia 2007), and African Penguins have also been recorded as far as 60 km offshore.

Figure 3-26: Cape Gannets Morus capensis (left) (Photo: NACOMA) and African Penguins Spheniscus demersus (right) (Photo: Klaus Jost) breed primarily on the offshore Islands.

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Table 3-3: Pelagic seabirds common in the southern Benguela region (Crawford et al. 1991).

Common Name Species name Global IUCN Shy albatross Thalassarche cauta Near Threatened Black browed albatross Thalassarche melanophrys Near Threatened Yellow nosed albatross Thalassarche chlororhynchos Endangered Giant petrel sp. Macronectes halli/giganteus Least concern Pintado petrel Daption capense Least concern Greatwinged petrel Pterodroma macroptera Least concern Soft plumaged petrel Pterodroma mollis Least concern Prion spp Pachyptila spp. Least concern White chinned petrel Procellaria aequinoctialis Vulnerable Cory’s shearwater Calonectris diomedea Least concern Great shearwater Puffinus gravis Least concern Sooty shearwater Puffinus griseus Near Threatened European Storm petrel Hydrobates pelagicus Least concern Leach’s storm petrel Oceanodroma leucorhoa Least concern Wilson’s storm petrel Oceanites oceanicus Least concern Blackbellied storm petrel Fregetta tropica Least concern Skua spp. Catharacta/Stercorarius spp. Least concern Sabine’s gull Larus sabini Least concern

Table 3-4: Breeding resident seabirds present along the West Coast (CCA & CMS 2001).

Common name Species name Global IUCN Status

African Penguin Spheniscus demersus Endangered Great Cormorant Phalacrocorax carbo Least Concern Cape Cormorant Phalacrocorax capensis Endangered Bank Cormorant Phalacrocorax neglectus Endangered Crowned Cormorant Microcarbo coronatus Near Threatened White Pelican Pelecanus onocrotalus Least Concern Cape Gannet Morus capensis Vulnerable Kelp Gull Larus dominicanus Least Concern Greyheaded Gull Larus cirrocephalus Least Concern Hartlaub's Gull Larus hartlaubii Least Concern Caspian Tern Hydroprogne caspia Vulnerable Swift Tern Sterna bergii Least Concern Roseate Tern Sterna dougallii Least Concern Damara Tern Sterna balaenarum Near Threatened

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Marine Mammals

The marine mammal fauna occurring off the southern African coast includes several species of whales and dolphins and one resident seal species.

Cetaceans (whales and dolphins) Thirty four species of whales and dolphins are known (based on historic sightings or strandings records) or likely (based on habitat projections of known species parameters) to occur in these waters (Table 3-5Table 3-5). The offshore areas have been particularly poorly studied with almost all available information from deeper waters (>200 m) arising from historic whaling records prior to 1970. Current information on the distribution, population sizes and trends of most cetacean species occurring on the west coast of southern Africa is lacking. Information on smaller cetaceans in deeper waters is particularly poor and the precautionary principal must be used when considering possible encounters with cetaceans in this area.

Records from stranded specimens show that the area between St Helena Bay (~32 S, 18 E) and Cape Agulhas (~34 S, 20 E) is an area of transition between Atlantic and Indian Ocean species, as well as those more commonly associated with colder waters of the west coast (e.g. dusky dolphins and long finned pilot whales) and those of the warmer east coast (e.g. striped and Risso’s dolphins) (Findlay et al. 1992). The project area lies north of this transition zone and can be considered to be truly on the ‘west coast’. However, the warmer waters that occur offshore of the Benguela ecosystem (more than ~100 km offshore) provide an entirely different habitat, that despite the relatively high latitude may host some species associated with the more tropical and temperate parts of the Atlantic such as rough toothed dolphins, Pan-tropical spotted dolphins and short finned pilot whales. Owing to the uncertainty of species occurrence offshore, species that may occur there have been included here for the sake of completeness.

The distribution of cetaceans can largely be split into those associated with the continental shelf and those that occur in deep, oceanic water. Cetacean density on the continental shelf is usually higher than in pelagic waters as species associated with the pelagic environment tend to be wide ranging across 1,000s of km. As the project target areas are located on the continental shelf, cetacean diversity in the area can be expected to be high. In the offshore portions of Concession 1C abundances will, however, be low compared to further inshore.

Cetaceans are comprised of two taxonomic groups, the mysticetes (filter feeders with baleen) and the odontocetes (predatory whales and dolphins with teeth). The term ‘whale’ is used to describe species in both groups and is taxonomically meaningless (e.g. the killer whale and pilot whale are members of the Odontoceti, family Delphinidae and are thus dolphins). Due to differences in sociality, communication abilities, ranging behavior and acoustic behavior, these two groups are considered separately.

Table 3-5 lists the cetaceans likely to be found within the project area, based on data sourced from: Findlay et al. (1992), Best (2007), Weir (2011), Dr J-P. Roux, (MFMR pers. comm.) and unpublished records held by the Namibian Dolphin Project. Of the 33 species listed, three are endangered and one is considered vulnerable (IUCN Red Data list Categories). Altogether 17 species are listed as “data deficient” underlining how little is known about cetaceans, their distributions and population trends. The majority of data available on the seasonality and distribution of large whales in the project area is the result of commercial whaling activities

Pisces Environmental Services (Pty) Ltd 57 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC mostly dating from the 1960s. Changes in the timing and distribution of migration may have occurred since these data were collected due to extirpation of populations or behaviours (e.g. migration routes may be learnt behaviours). The large whale species for which there are current data available are the humpback and southern right whale, although almost all data is limited to that collected on the continental shelf close to shore.

A review of the distribution and seasonality of the key cetacean species likely to be found within the project area is provided below.

Mysticete (Baleen) whales The majority of mysticetes whales fall into the family Balaenopeteridae. Those occurring in the area include the blue, fin, sei, Antarctic minke, dwarf minke, humpback and Bryde’s whales. The southern right whale (Family Balaenidae) and pygmy right whale (Family Neobalaenidae) are from taxonomically separate groups. The majority of mysticete species occur in pelagic waters with only occasional visits to shelf waters. All of these species show some degree of migration either to or through the latitudes encompassed by the broader project area when en route between higher latitude (Antarctic or Subantarctic) feeding grounds and lower latitude breeding grounds. Depending on the ultimate location of these feeding and breeding grounds, seasonality may be either unimodal, usually in winter months, or bimodal (e.g. May to July and October to November), reflecting a northward and southward migration through the area. Northward and southward migrations may take place at different distances from the coast due to whales following geographic or oceanographic features, thereby influencing the seasonality of occurrence at different locations. Because of the complexities of the migration patterns, each species is discussed separately below.

Two genetically and morphologically distinct populations of Bryde’s whales (Figure 3-27, left) live off the coast of southern Africa (Best 2001; Penry 2010). The “offshore population” lives beyond the shelf (>200 m depth) off west Africa and migrates between wintering grounds off equatorial west Africa (Gabon) and summering grounds off western South Africa. Its seasonality on the west coast is thus opposite to the majority of the balaenopterids with abundance likely to be highest in the broader project area in January - March. The “inshore population” of Bryde’s, which lives on the continental shelf and Agulhas Bank, is unique amongst baleen whales in the region by being non-migratory. It may move further north into the Benguela current areas of the west of coast of South Africa and Namibia, especially in the winter months (Best 2007).

Sei whales migrate through South African waters, where they were historically hunted in relatively high numbers, to unknown breeding grounds further north. Their migration pattern thus shows a bimodal peak with numbers west of Cape Columbine highest in May and June, and again in August, September and October. All whales were caught in waters deeper than 200 m with most caught deeper than 1,000 m (Best & Lockyer 2002). Almost all information is based on whaling records 1958-1963 and there is no current information on abundance or distribution patterns in the region.

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Table 3-5: Cetaceans occurrence off the West Coast of South Africa, their seasonality, likely encounter frequency with offshore mining operations and IUCN conservation status.

Likely IUCN Common Name Species Shelf Offshore Seasonality encounter Conservation frequency Status Delphinids Dusky dolphin Lagenorhynchus obscurus Yes (0- 800 m) No Year round Daily Data Deficient Heaviside’s dolphin Cephalorhynchus heavisidii Yes (0-200 m) No Year round Daily Data Deficient Common bottlenose dolphin Tursiops truncatus Yes Yes Year round Monthly Least Concern Common (short beaked) dolphin Delphinus delphis Yes Yes Year round Monthly Least Concern Southern right whale dolphin Lissodelphis peronii Yes Yes Year round Occasional Data Deficient Striped dolphin Stenella coeruleoalba No ? ? Very rare Least Concern Pantropical spotted dolphin Stenella attenuata Edge Yes Year round Very rare Least Concern Long-finned pilot whale Globicephala melas Edge Yes Year round

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Likely IUCN Common Name Species Shelf Offshore Seasonality encounter Conservation frequency Status Beaked whales Cuvier’s Ziphius cavirostris No Yes Year round Occasional Data Deficient Arnoux’s Beradius arnouxii No Yes Year round Occasional Data Deficient Southern bottlenose Hyperoodon planifrons No Yes Year round Occasional Least Concern Layard’s Mesoplodon layardii No Yes Year round Occasional Data Deficient True’s M. mirus No Yes Year round Data Deficient Gray’s M. grayi No Yes Year round Occasional Data Deficient Blainville’s M. densirostris No Yes Year round Data Deficient Baleen whales Antarctic Minke Balaenoptera bonaerensis Yes Yes >Winter Monthly Least Concern Dwarf minke B. acutorostrata Yes Yes Year round Occasional Least Concern Fin whale B. physalus Yes Yes MJJ & ON, rarely Occasional Endangered in summer Blue whale B. musculus No Yes ? Occasional Endangered Sei whale B. borealis Yes Yes MJ & ASO Occasional Endangered Bryde’s (offshore) B. brydei Yes Yes Summer (JF) Occasional Data Deficient Bryde’s (inshore) B brydei (subspp) Yes Yes Year round Occasional Data Deficient Pygmy right Caperea marginata Yes ? Year round Occasional Least Concern Humpback Megaptera novaeangliae Yes Yes Year round, higher Daily* Least Concern in SONDJF Southern right Eubalaena australis Yes No Year round, higher Daily* Least Concern in SONDJF

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Figure 3-27: The Bryde’s whale Balaenoptera brydei (left) and the Minke whale Balaenoptera bonaerensis (right) (Photos: www.dailymail.co.uk; www.marinebio.org).

Fin whales were historically caught off the West Coast of South Africa, with a bimodal peak in the catch data suggesting animals were migrating further north during May-June to breed, before returning during August-October en route to Antarctic feeding grounds. Some juvenile animals may feed year round in deeper waters off the shelf (Best 2007). There are no recent data on abundance or distribution of fin whales off western South Africa.

Although blue whales were historically caught in high numbers off the South African West Coast, there have been only two confirmed sightings of the species in the area since 1973 (Branch et al. 2007), suggesting that the population using the area may have been extirpated by whaling. However, scientific search effort (and thus information) in pelagic waters is very low. The chance of encountering the species in the mining right areas is considered low.

Two forms of minke whale (Figure 3-27, right) occur in the southern Hemisphere, the Antarctic minke whale (Balaenoptera bonaerensis) and the dwarf minke whale (B. acutorostrata subsp.); both species occur in the Benguela (Best 2007). Antarctic minke whales range from the pack ice of Antarctica to tropical waters and are usually seen more than ~50 km offshore. Although adults migrate from the Southern Ocean (summer) to tropical/temperate waters (winter) to breed, some animals, especially juveniles, are known to stay in tropical/temperate waters year round. The dwarf minke whale has a more temperate distribution than the Antarctic minke and they do not range further south than 60-65°S. Dwarf minkes have a similar migration pattern to Antarctic minkes with at least some animals migrating to the Southern Ocean during summer. Dwarf minke whales occur closer to shore than Antarctic minkes. Both species are generally solitary and densities are likely to be low in the project area.

The most abundant baleen whales in the Benguela are southern right whales and humpback whales (Figure 3-28). In the last decade, both species have been increasingly observed to remain on the west coast of South Africa well after the ‘traditional’ South African whale season (June – November) into spring and early summer (October – February) where they have been observed feeding in upwelling zones, especially off Saldanha and St Helena Bay (Barendse et al. 2011; Mate et al. 2011).

The majority of humpback whales passing through the Benguela are migrating to breeding grounds off tropical west Africa, between Angola and the Gulf of Guinea (Rosenbaum et al. 2009; Barendse et al. 2010). In coastal waters, the northward migration stream is larger than

Pisces Environmental Services (Pty) Ltd 61 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC the southward peak (Best & Allison 2010; Elwen et al. 2013), suggesting that animals migrating north strike the coast at varying places north of St Helena Bay, resulting in increasing whale density on shelf waters and into deeper pelagic waters as one moves northwards, but no clear migration ‘corridor’. On the southward migration, many humpbacks follow the Walvis Ridge offshore then head directly to high latitude feeding grounds, while others follow a more coastal route (including the majority of mother-calf pairs) possibly lingering in the feeding grounds off west South Africa in summer (Elwen et al. 2013, Rosenbaum et al. 2014). Recent abundance estimates put the number of animals in the west African breeding population to be in excess of 9,000 individuals in 2005 (IWC 2012) and it is likely to have increased since this time at about 5% per annum (IWC 2012). Humpback whales are thus likely to be the most frequently encountered baleen whale in the project area, ranging from the coast out beyond the shelf, with year round presence but numbers peaking in July – February associated with the breeding migration and subsequent feeding in the Benguela.

Figure 3-28: The Humpback whale Megaptera novaeangliae (left) and the Southern Right whale Eubalaena australis (right) are the most abundant large cetaceans occurring along the southern African West Coast (Photos: www.divephotoguide.com; www.aad.gov.au).

The southern African population of southern right whales historically extended from southern Mozambique (Maputo Bay) to southern Angola (Baie dos Tigres) and is considered to be a single population within this range (Roux et al. 2011). The most recent abundance estimate for this population is available for 2008 which estimated the population at ~4,600 individuals including all age and sex classes, which is thought to be at least 23% of the original population size (Brandaõ et al. 2011). Since the population is still continuing to grow at ~7% per year (Brandaõ et al. 2011), the population size in 2013 would number more than 6,000 individuals. When the population numbers crashed, the range contracted down to just the south coast of South Africa, but as the population recovers, it is repopulating its historic grounds including Namibia (Roux et al. 2001) and Mozambique (Banks et al. 2011). Southern right whales are seen regularly in the nearshore waters of the West Coast (<3 km from shore), extending north into southern Namibia (Roux et al. 2001, 2011). Southern right whales have been recorded off the West Coast in all months of the year, but with numbers peaking in winter (June - September).

In the last decade, deviations from the predictable and seasonal migration patterns of these two species have been reported from the Cape Columbine – Yzerfontein area (Best 2007; Barendse et al. 2010). High abundances of both Southern Right and Humpback whales in this

Pisces Environmental Services (Pty) Ltd 62 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC area during spring and summer (September-February), indicates that the upwelling zones off Saldanha and St Helena Bay may serve as an important summer feeding area (Barendse et al. 2011, Mate et al. 2011). It was previously thought that whales feed only rarely while migrating (Best et al. 1995), but these localised summer concentrations suggest that these whales may in fact have more flexible foraging habits.

Odontocetes (toothed) whales The Odontoceti are a varied group of animals including the dolphins, porpoises, beaked whales and sperm whales. Species occurring within the broader project area display a diversity of features, for example their ranging patterns vary from extremely coastal and highly site specific to oceanic and wide ranging. Those in the region can range in size from 1.6-m long (Heaviside’s dolphin) to 17 m (bull sperm whale).

All information about sperm whales in the southern African sub-region results from data collected during commercial whaling activities prior to 1985 (Best 2007). Sperm whales are the largest of the toothed whales and have a complex, structured social system with adult males behaving differently to younger males and female groups. They live in deep ocean waters, usually greater than 1,000 m depth, although they occasionally come onto the shelf in water 500 - 200 m deep (Best 2007) (Figure 3-29, left). They are considered to be relatively abundant globally (Whitehead 2002), although no estimates are available for South African waters. Seasonality of catches suggests that medium and large sized males are more abundant in winter months while female groups are more abundant in autumn (March - April), although animals occur year round (Best 2007). Sperm whales are thus likely to be encountered in relatively high numbers in deeper waters (>500 m), predominantly in the winter months (April - October). Sperm whales feed at great depths during dives in excess of 30 minutes making them difficult to detect visually, however the regular echolocation clicks made by the species when diving make them relatively easy to detect acoustically using Passive Acoustic Monitoring (PAM).

Figure 3-29: Sperm whales Physeter macrocephalus (left) and killer whales Orcinus orca (right) are toothed whales likely to be encountered in offshore waters (Photos: www.onpoint.wbur.org; www.wikipedia.org).

There are almost no data available on the abundance, distribution or seasonality of the smaller odontocetes (including the beaked whales and dolphins) known to occur in oceanic waters (>200 m) off the shelf of the southern African West Coast. Beaked whales are all considered to

Pisces Environmental Services (Pty) Ltd 63 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC be true deep water species usually being seen in waters in excess of 1,000-2,000 m deep (see various species accounts in Best 2007). Presence in the project area may fluctuate seasonally, but insufficient data exist to define this clearly.

The genus Kogia currently contains two recognised species, the pygmy (K. breviceps) and dwarf (K. sima) sperm whales, both of which most frequently occur in pelagic and shelf edge waters, although their seasonality is unknown. The majority of what is known about Kogiidae whales in the southern African subregion results from studies of stranded specimens (e.g. Ross 1979; Findlay et al. 1992; Plön 2004; Elwen et al. 2013).

Killer whales (Figure 3-29 right) have a circum-global distribution being found in all oceans from the equator to the ice edge (Best 2007). Killer whales occur year round in low densities off western South Africa (Best et al. 2010), Namibia (Elwen & Leeney 2011) and in the Eastern Tropical Atlantic (Weir et al. 2010). Killer whales are found in all depths from the coast to deep open ocean environments and may thus be encountered in the project area at low levels.

The false killer whale has a tropical to temperate distribution and most sightings off southern Africa have occurred in water deeper than 1,000 m, but with a few recorded close to shore (Findlay et al. 1992). They usually occur in groups ranging in size from 1 - 100 animals (Best 2007). The strong bonds and matrilineal social structure of this species makes it vulnerable to mass stranding (8 instances of 4 or more animals stranding together have occurred in the western Cape, all between St Helena Bay and Cape Agulhas). There is no information on population numbers or conservation status and no evidence of seasonality in the region (Best 2007).

Long-finned pilot whales display a preference for temperate waters and are usually associated with the continental shelf or deep water adjacent to it (Mate et al. 2005; Findlay et al. 1992; Weir 2011). They are regularly seen associated with the shelf edge by marine mammal observers (MMOs) and fisheries observers and researchers. The distinction between long-finned and short-finned pilot whales is difficult to make at sea. As the latter are regarded as more tropical species (Best 2007), it is likely that the vast majority of pilot whales encountered in the project area will be long-finned.

The common dolphin is known to occur offshore in West Coast waters (Findlay et al. 1992; Best 2007), although the extent to which they occur in the project area is unknown, but likely to be low. Group sizes of common dolphins can be large, averaging 267 (± SD 287) for the South Africa region (Findlay et al. 1992). They are more frequently seen in the warmer waters offshore and to the north of the country, seasonality is not known.

In water <500 m deep, dusky dolphins (Figure 3-30, right) are likely to be the most frequently encountered small cetacean as they are very “boat friendly” and often approach vessels to bowride. The species is resident year round throughout the Benguela ecosystem in waters from the coast to at least 500 m deep (Findlay et al. 1992). Although no information is available on the size of the population, they are regularly encountered in near shore waters between Cape Town and Lamberts Bay (Elwen et al. 2010a; NDP unpubl. data) with group sizes of up to 800 having been reported (Findlay et al. 1992). A hiatus in sightings (or low density area) is reported between ~27S and 30S, associated with the Lüderitz upwelling cell (Findlay et al. 1992). Dusky dolphins are resident year round in the Benguela.

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Heaviside’s dolphins (Figure 3-30, left) are relatively abundant in the Benguela ecosystem region with 10,000 animals estimated to live in the 400 km of coast between Cape Town and Lamberts Bay (Elwen et al. 2009). This species occupies waters from the coast to at least 200 m depth, (Elwen et al. 2006; Best 2007), and may show a diurnal onshore-offshore movement pattern (Elwen et al. 2010b), but this varies throughout the species range. Heaviside’s dolphins are resident year round.

Figure 3-30: The endemic Heaviside’s Dolphin Cephalorhynchus heavisidii (left) (Photo: De Beers Marine Namibia), and Dusky dolphin Lagenorhynchus obscurus (right) (Photo: scottelowitzphotography.com).

Several other species of dolphins that might occur in deeper waters at low levels include the pygmy killer whale, Risso’s dolphin, rough toothed dolphin, pan tropical spotted dolphin and striped dolphin (Findlay et al. 1992; Best 2007). Nothing is known about the population size or density of these species in the project area but encounters are likely to be rare.

Beaked whales were never targeted commercially and their pelagic distribution makes them the most poorly studied group of cetaceans. With recorded dives of well over an hour and in excess of 2 km deep, beaked whales are amongst the most extreme divers of any air breathing animals (Tyack et al. 2011). They also appear to be particularly vulnerable to certain types of anthropogenic noise, although reasons are not yet fully understood. All the beaked whales that may be encountered in the project area are pelagic species that tend to occur in small groups usually less than five, although larger aggregations of some species are known (MacLeod & D’Amico 2006; Best 2007).

In summary, the humpback and southern right whale are likely to be encountered year-round, with numbers in the Cape Columbine area highest between September and February, and not during winter as is common on the South Coast breeding grounds. Several other large whale species are also most abundant on the West Coast during winter: fin whales peak in May-July and October-November; sei whale numbers peak in May-June and again in August-October and offshore Bryde’s whale numbers are likely to be highest in January-February. Whale numbers on the shelf and in offshore waters are thus likely to be highest between October and February.

Of the migratory cetaceans, the Blue, Sei and Humpback whales are listed as “Endangered” and the Southern Right and Fin whale as “Vulnerable” in the IUCN Red Data book. All whales and dolphins are given protection under the South African Law. The Marine Living Resources

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Act, 1998 (No. 18 of 1998) states that no whales or dolphins may be harassed, killed or fished. No vessel or aircraft may, without a permit or exemption, approach closer than 300 m to any whale and a vessel should move to a minimum distance of 300 m from any whales if a whale surfaces closer than 300 m from a vessel or aircraft.

Seals The Cape fur seal (Arctocephalus pusillus pusillus) (Figure 3-31) is the only species of seal resident along the west coast of Africa, occurring at numerous breeding and non-breeding sites on the mainland and on nearshore islands and reefs (see Figure 3-35). Vagrant records from four other species of seal more usually associated with the subantarctic environment have also been recorded: southern elephant (Mirounga leoninas), subantarctic fur (Arctocephalus tropicalis), crabeater (Lobodon carcinophagus) and leopard seals (Hydrurga leptonyx) (David 1989).

There are a number of Cape fur seal colonies within the study area: at Kleinzee (incorporating Robeiland), at Bucchu Twins near Alexander Bay, and Strandfontein Point (south of Hondeklipbaai). The colony at Kleinzee has the highest seal population and produces the highest seal pup numbers on the South African Coast (Wickens 1994). The colony at Buchu Twins, formerly a non-breeding colony, has also attained breeding status (M. Meyer, DAFF, pers. comm.). Non-breeding colonies occur south of Hondeklip Bay at Strandfontein Point and on Bird Island at Lamberts Bay, with the McDougall’s Bay islands and Wedge Point being haul- out sites only and not permanently occupied by seals. All have important conservation value since they are largely undisturbed at present. Seals are highly mobile animals with a general foraging area covering the continental shelf up to 120 nautical miles offshore (Shaughnessy 1979), with bulls ranging further out to sea than females. The timing of the annual breeding cycle is very regular, occurring between November and January. Breeding success is highly dependent on the local abundance of food, territorial bulls and lactating females being most vulnerable to local fluctuations as they feed in the vicinity of the colonies prior to and after the pupping season (Oosthuizen 1991).

Figure 3-31: Colony of Cape fur seals Arctocephalus pusillus pusillus (Photo: Dirk Heinrich).

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3.4. Other Uses of the Area 3.4.1 Beneficial Uses The mining licence areas extend from the shore to approximately 120 m depth. Other users of these areas include other marine diamond mining concession holders, hydrocarbon exploration and production licences, the commercial and recreational fishing industries and kelp collection concessions. 3.4.1.1 Diamond Mining

The coastal mining licence areas extend some distance inland, and as a consequence public access to the coast is restricted, and recreational activities between Alexander Bay and Hondeklipbaai is limited to the area around Port Nolloth and McDougall’s Bay.

The marine diamond mining concession areas are split into four or five zones (Surf zone and (a) to (c) or (d)-concessions), which together extend from the high water mark out to approximately 500 m depth (see Figure 3-32). No deep-water diamond mining is currently underway in the adjacent South African offshore concession areas, since mining activities in De Beers Marine’s Mining Licence (SASA MPT 25/2011) ceased in 2010. In Namibian waters, to the north and adjacent to Concessions 1B and 1C, deep-water diamond mining by De Beers Marine Namibia is currently operational in the Atlantic 1 Mining Licence Area.

These mining operations are typically conducted to depths of 150 m from fully self-contained mining vessels with on board processing facilities, using either large-diameter drill or seabed crawler technology.

Prospecting rights for heavy minerals, gold platinum group elements and sapphire have also been granted to De Beers Consolidated Mines (Pty) Ltd within Sea Concession 2C-10C, and there are a number of proposed prospecting areas for glauconite and phosphorite / phosphate, all of which are located south of the mining licence area.

3.4.1.2 Hydrocarbons

The South African continental shelf and economic exclusion zone (EEZ) have similarly been partitioned into Licence blocks for petroleum exploration and production activities. Exploration has included extensive 2D and 3D seismic surveys and the drilling of numerous exploration wells, with ~40 wells having been drilled in the Namaqua Bioregion since 1976 (Figure 3-33). The majority of these occur in the iBhubesi gas field in Block 2A. Prior to 1983, technology was not available to remove wellheads from the seafloor and currently 35 wellheads remain on the seabed.

Although no wells have recently been drilled in the area, further exploratory drilling is proposed for inshore and offshore portions of Block 1, with further target areas in Block 2B and the Orange Basin (although the licence holder has recently relinquished this block). A subsea pipeline to export gas from the iBhubesi field to a location either on the Cape Columbine peninsula or to Ankerlig ~25 km north of Cape Town is also proposed.

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Figure 3-32: Project - environment interaction points on the West Coast, illustrating the location of marine diamond mining concessions and ports for commercial and fishing vessels, in relation to the Mining Licence Areas.

3.4.1.3 Kelp Collecting

The West Coast is divided into numerous seaweed concession areas (see Figure 3-34). The 1A, 2A, 3A and 4A mining licence areas overlap with seaweed concessions 18, 16 and 19. Access to a seaweed concession is granted by means of a permit from the Fisheries Branch of the Department of Agriculture, Forestry and Fisheries to a single party for a period of five years. The seaweed industry was initially based on sun dried beach-cast seaweed, with harvesting of fresh seaweed occurring in small quantities only (Anderson et al. 1989). The actual level of beach-cast kelp collection varies substantially through the year, being dependent on storm action to loosen kelp from subtidal reefs (Table 3-6). Permit holders collect beach casts of the both Ecklonia maxima and Laminaria pallida from the driftline of beaches. The kelp is initially dried just above the high water mark before being transported to drying beds in the foreland dune area. The dried product is ground before being exported for production of alginic acid (alginate). In the areas around abalone hatcheries fresh beach-cast kelp is also collected as food for cultured abalone, although quantities have not been reported to the Department of Agriculture, Forestry and Fisheries (DAFF).

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Figure 3-33: Project - environment interaction points on the West Coast, illustrating the location of hydrocarbon lease blocks, existing well heads, proposed areas for exploratory wells and the routing of the proposed iBhubesi gas export pipeline, in relation to the Mining Licence Areas (red polygons).

Further south, around Cape Columbine, permits also allow the harvesting of live kelp by hand from a boat. Two methods of harvesting are practiced. The first involves the removal of the whole kelp primary blade and fronds thereby killing the plant. The second method involves harvesting the distal frond only, allowing the frond to re-grow thereby resulting in a 4-5 times greater yield of frond material over the long term (Levitt et al. 2002; Rand 2006). As only those plants that reach the surface at low tide are cut this practice is restricted to kelp beds further south that are dominated by Ecklonia. No kelp plants with a stipe <50 cm long may be cut or harmed. The Maximum Sustainable Yield (MSY) for the harvested product is set annually (Anderson et al. 2003) and is based on the estimated kelp biomass in the concession area determined from the total area of kelp beds and the mean biomass within them (Table 3-7).

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Table 3-6: Beach-cast collections (in kg dry weight) for kelp concessions north of Lamberts Bay (Data source: Seaweed Section, DAFF).

Concession Number 13 14 15 16 18 19

Concession Eckloweed Eckloweed Rekaofela Rekaofela Premier FAMDA Holder Industries Industries Kelp Kelp Fishing 2005 65,898 165,179 10,300 35,920 0 0 2006 94,914 145,670 19,550 28,600 0 0 2007 122,095 79,771 0 84,445 0 0 2008 61,949 204,365 23,646 16,804 0 0 2009 102,925 117,136 0 0 0 0 2010 53,927 166,106 0 0 0 0 2011 40,511 72,829 0 0 0 0 2012 43,297 151,561 160,500 156,000 0 0 2013 20,485 97,283 36,380 24,000 0 0 2014 19,335 136,266 74,300 75,743 0 0 2015 52,827 158,184 0 0 0 0 2016 69,363 154,010 0 0 0 0

Table 3-7: The estimated total area of kelp beds for each of the kelp concessions between the Orange River mouth and Cape Columbine (Rand 2006).

Length of rocky Kelp Concession/Area Kelp bed area (ha) coastline (km) 19 254.95 48.5 18 976.0 18.25 16 206.44 5.0 15 732.22 104.5 Groen-Spoeg 71.94 ~15.0 14 206.64 63.75 13 10.8 4.25 Strandfontein no data ~15 12 15.9 1.25 11 617.95 28.75

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Figure 3-34: Estimated kelp bed area in the South African kelp concessions between the Orange River mouth and Cape Columbine (from Penney et al. 2008).

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3.4.1.4 Large-scale Commercial Fisheries

The demersal trawl fishery, which targets the Cape hakes (Merluccius capensis and M. paradoxus), monkfish (Lophius vomerinus), kingklip (Genypterus capensis) and snoek (Thyrsites atun), operates between the 220 m and 580 m isobaths and thus well offshore of the 1C mining licence area. The fishing grounds for the hake-directed long-line fishery are similarly situated between the 200 m and 500 m isobaths, whereas the large pelagic long-line fishery operates seawards of the 500 m isobath (Wilkinson & Japp 2014). The tuna pole fishery, which primarily targets southern Atlantic longfin tuna (Thunnus alalunga) and a very small amount of skipjack tuna (Katsuwonus pelamis), yellowfin tuna and bigeye tuna, primarily operates beyond the 200 m isobaths, although some catches have been reported from around the 100 m isobaths offshore and to the north of Port Nolloth thereby potentially overlapping with the 1B and 1C mining licence areas. The fishery is seasonal with vessel activity mostly between December and May and peak catches in February and March. Activities of the commercial linefishery and small-pelagic purse-seine fishery are all focussed well south of the mining licence areas (Wilkinson & Japp 2014).

3.4.1.5 Rock Lobster Fishery

The West Coast rock lobster Jasus lalandii is a valuable resource of the South African West Coast and consequently an important income source for West Coast fishermen. Following the collapse of the rock-lobster resource in the early 1990s, fishing has been controlled by a Total Allowable Catch (TAC), a minimum size, restricted gear, a closed season and closed areas (Crawford et al. 1987, Melville-Smith et al. 1995). The fishery is divided into the offshore fishery (30 m to 100 m depth) and the near-shore fishery (< 30 m depth), thereby overlapping with the mining licence areas. Management of the resource is geographically specific, with the TAC annually allocated by Area. The mining licence areas fall within Management Area 1 of the commercial rock lobster fishing zones, which extends from the Orange River Mouth to Kleinzee. Area 2 extends from Kleinzee to the mouth of the Brak River. The fishery operates seasonally, with closed seasons applicable to different zones; Management Areas 1 and 2 operate from 1 October to 30 April.

Commercial catches of rock lobster in Area 1 are confined to shallower water (<30 m) with almost all the catch being taken in <15 m depth, therefore overlapping directly with diver- assisted vessel-based mining operations. Actual rock-lobster fishing, however, takes place only at discrete suitable reef areas along the shore within this broad depth zone. Lobster fishing is conducted from a fleet of small dinghies/bakkies. The majority of these work directly from the shore within a few nautical miles of the harbours, with only 30% of the total numbers of bakkies partaking in the fishery being deployed from larger deck boats. As a result, lobster fishing tends to be concentrated close to the shore within a few nautical miles of Port Nolloth and Hondeklip Bay. Landings of rock lobster recorded within Area 1 have been reported at an average total rock lobster tail weight of 16 tons per year (2008 – 2012). All landings were reported by bakkies, with no landings made by the offshore sector. This amounts to 0.8% of the total landings recorded by the West Coast rock lobster fishery (inclusive of both the near- shore and offshore fisheries) and 4.1% of the total landings recorded by the bakkie fleet.

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Rock lobster landings from Areas 1 and 2 for the years 2006 to 2017 are provided in Table 3-8.

Table 3-8: Total Allowable Catch (TAC) and Actual landed catch (kgs) for Areas 1 and 2 in the Northern Cape during the 2005/06 to 2016/2017 fishing seasons (Data source: Rock Lobster Section, DAFF).

Year TAC Area 1 Area 2

2006 30,000 27,595 40 2007 30,000 14,983 1,487 2008 30,000 21,901 1,764 2009 24,000 20,891 1,345 2010 24,000 15,482 2,089 2011 24,000 8,223 1,406 2012 24,000 4,680 801 2013 24,000 6,242 0 2014 24,000 8,960 541 2015 20,000 3,163 961 2016 24,000 6,201 717 2017 24,000 2,966 119

3.4.1.6 Recreational Fisheries

Recreational and subsistence fishing on the West Coast is small in scale when compared with the south and east coasts of South Africa. The population density in Namaqualand is low, and poor road infrastructure and ownership of much of the land by diamond companies in the northern parts of the West Coast has historically restricted coastal access to the towns and recreational areas of Port Nolloth, McDougall’s Bay, Hondeklipbaai and the Groenrivier mouth.

Recreational line-fishing is confined largely to rock and surf angling in places such as Brand-se- Baai, well to the south of the mining licence areas, and the more accessible coastal stretches in the regions. Boat angling is not common along this section of the coast due to the lack of suitable launch sites and the exposed nature of the coastline. Fishing effort has been estimated at 0.12 angler/km north of Doringbaai. These fishers expended effort of approximately 200,000 angler days/year with a catch-per-unit-effort of 0.94 fish/angler/day (Brouwer et al. 1997; Sauer & Erasmus 1997). Traget species consist mostly of hottentot, white stumpnose, kob, steenbras and galjoen, with catches being used for domestic consumption, or are sold.

Recreational rock lobster catches are made primarily by diving or shore-based fishing using baitbags. Hoop-netting for rock lobster from either outboard or rowing boats is not common along this section of the coast (Cockcroft & McKenzie 1997). Most of the recreational catch is made early in the season, with 60% of the annual catch landed by the end of January. The majority of the recreational take of rock lobster (~68%) is made by locals resident in areas close to the resource. Due to the remoteness of the area and the lack of policing, poaching of rock lobsters by the locals, seasonal visitors as well as the shore-based mining units is becoming an increasing problem. Large numbers of rock lobsters are harvested in sheltered bays along the Namaqualand coastline by recreational divers who disregard bag-limits, size-limits or

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3.4.1.7 Mariculture

Although the Northern Cape coast lies beyond the northern-most distribution limit of abalone (Haliotis midae) on the West Coast, ranching experiments have been undertaken in the region since 1995 (Sweijd et al. 1998, de Waal & Cook 2001, de Waal 2004). As some sites have shown high survival of seeded juveniles, the Department of Agriculture, Forestry and Fisheries (DAFF) published criteria for allocating rights to engage in abalone ranching or stock enhancement (Government Gazette No. 33470, Schedule 2, 20 August 2010) in four areas along the Namaqualand Coast (Table 3-9). Ranching in these areas is currently being investigated at the pilot phase. The PSJV 1A, 2A, 3A and 4A concessions overlap with areas NC1 and NC2.

Associated with the ranching projects are land-based abalone hatcheries located at North Point near Port Nolloth, at Kleinzee and at Hondeklipbaai. These hatcheries operate on a semi- recirculation system using seawater pumped from the shallow subtidal zone to top-up the holding tanks (Anchor Environmental Consultants 2010).

Table 3-9: Allocated abalone ranching areas in the Northern Cape.

Area Description Latitude Longitude Rights Holder

Boegoeberg North 28°45′41.35″S 16°33′41.93″E NC1 Turnover Trading Beach north of North Point 29°14′07.65″S 16°51′14.08″E South-end of McDougall Bay 29°17′34.23″S 16°52′32.08″E Really Useful NC2 Rob Island 29°40′07.12″S 16°59′50.45″E Investments No 72 Beach at Kleinzee 29°43′43.09″S 17°03′03.50″E Port Nolloth Sea NC3 Swartduine 30°02′52.04″S 17°10′39.69″E Farms Skulpfontein 30°06′08.15″S 17°11′08.03″E Diamond Coast NC4 2 rocks 200 m from shore 30°25′56.26″S 17°20′05.43″E Abalone

3.4.2 Conservation Areas and Marine Protected Areas Numerous conservation areas and marine protected areas (MPA) exist along the West Coast, although none fall within the PSJV concessions. For the sake of completeness, they are briefly summarised below.

The Rocher Pan MPA, which stretches 500 m offshore of the high water mark of the adjacent Rocher Pan Nature Reserve, was declared in 1966. The MPA primarily protects a stretch of beach important as a breeding area to numerous waders. This MPA is located between Lamberts Bay and Velddrif, ~360 km to the south of the Mining Right areas.

The West Coast National Park, which was established in 1985 incorporates the Langebaan Lagoon and Sixteen Mile Beach MPAs, as well the islands Schaapen (29 ha), Marcus (17 ha), Malgas (18 ha) and Jutten (43 ha). These MPAs are located ~400 km to the south of the Mining Right areas. Langebaan Lagoon was designated as a Ramsar site in April 1988 under the Convention on Wetlands of International Importance especially as Waterfowl Habitat. The

Pisces Environmental Services (Pty) Ltd 74 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC lagoon is divided into three different utilization zones namely: wilderness, limited recreational and multi-purpose recreational areas. The wilderness zone has restricted access and includes the southern end of the lagoon and the inshore islands, which are the key refuge sites of the waders and breeding seabird populations respectively. The limited recreation zone includes the middle reaches of the lagoon, where activities such as sailing and canoeing are permitted. The mouth region is a multi-purpose recreation zone for power boats, yachts, water-skiers and fishermen. However, no collecting or removal of abalone and rock lobster is allowed. The length of the combined shorelines of Langebaan Lagoon MPA and Sixteen Mile Beach is 66 km. The uniqueness of Langebaan lies in its being a warm oligotrophic lagoon, along the cold, nutrient-rich and wave exposed West Coast.

No rock lobster may be caught in Saldanha Bay eastwards of a line between North Head and South Head. There is also a Rock Lobster Sanctuary in St Helena Bay. Further marine conservation areas in the Saldanha/Cape Columbine region include:

 Paternoster Rocks – Egg and Seal Island reserves for seabirds and seals  Jacob’s Reef - Island reserve for seabirds and seals  An area within the military base, SAS Saldanha  Vondeling Island

The only conservation area in the Northern Cape in which restrictions apply is the McDougall’s Bay rock lobster sanctuary near Port Nolloth, which is closed to exploitation of rock lobsters (Figure 3-35). The sanctuary, which extends one nautical mile seawards of the high water mark between the promontory at the northern end of McDougall's Bay, and the promontory at the southern extremity of McDougall's Bay, overlaps with Concession 3A.

Using biodiversity data mapped for the 2004 and 2011 National Biodiversity Assessments a systematic biodiversity plan was developed for the West Coast with the objective of identifying coastal and offshore priority focus areas for MPA expansion (Sink et al. 2011; Majiedt et al. 2013) and both coastal and offshore priority areas for MPA expansion were identified. To this end, numerous offshore focus areas were identified for protection on the South African West Coast between Cape Columbine and the South African – Namibian border. These focus areas were carried forward during Operation Phakisa, which identified potential MPAs. The draft regulations for the proposed MPAs were published in February 2016 and are currently out for review. Potentially vulnerable marine ecosystems (VMEs) that were explicitly considered during the planning included the shelf break, seamounts, submarine canyons, hard grounds, submarine banks, deep reefs and cold water coral reefs. Those proposed MPAs within the broad project area are shown in Figure 3-35.

Of principal importance in the general project area is the proposed Namaqua Fossil Forest MPA, situated about 30 km offshore between Port Nolloth and Kleinsee in 135-140 m depth. The small seabed outcrop (~2 km2), which is unique to the area, is composed of fossilised yellow- wood trees colonized by fragile, habitat forming scleractinian corals. This area lies well offshore of Concession 4B.

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Figure 3-35: Project - environment interaction points on the West Coast, illustrating the location of seabird and seal colonies and resident whale populations in relation to the Mining Licence Areas (red polygons). Proposed MPAs identified by Operation Phakisa are also shown.

In the spatial marine biodiversity assessment undertaken for Namibia (Holness et al. 2014), the Orange Shelf Edge area, which includes Tripp Seamount and a shelf-indenting submarine canyon, was identified as being of high priority for place-based conservation measures. To this end, an Ecologically or Biologically Significant Area (EBSA) spanning the border between Namibia and South Africa was proposed and inscribed under the Convention of Biological Diversity (CBD). The EBSA comprises shelf/shelf edge habitat with hard and unconsolidated substrates, including at least eleven offshore benthic habitat types of which four habitat types are ‘Threatened’, one is ‘Critically Endangered’ and one ‘Endangered’. The proposed Orange Shelf Edge EBSA is one of few places where these threatened habitat types are in relatively natural/pristine condition. The local habitat heterogeneity is also thought to contribute to the Orange Shelf Edge being a persistent hotspot of species richness for demersal fish species. Although focussed primarily on the conservation of benthic biodiversity and threatened benthic habitats, the EBSA also considers the pelagic habitat, which is characterized by medium productivity, cold to moderate Atlantic temperatures (SST mean = 18.3°C) and moderate chlorophyll levels related to the eastern limit of the Benguela upwelling on the outer shelf. A more focussed version of the EBSA has been submitted and is currently undergoing discussions at national and transboundary level, following which it will be submitted to the CBD for official recognition at the Review Workshop scheduled for early 2018. The principal objective of the EBSA is identification of features of higher ecological value that may require enhanced conservation and management measures. No specific management actions have been

Pisces Environmental Services (Pty) Ltd 76 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC formulated for the Orange Shelf Edge area at this stage. The area lies well offshore of the mining licence areas.

3.4.3 Threat Status and Vulnerable Marine Ecosystems ‘No-take’1 MPAs offering protection of the Namaqua biozones (sub-photic, deep-photic, shallow-photic, intertidal and supratidal zones) are absent northwards from Cape Columbine (Emanuel et al. 1992, Lombard et al. 2004). Rocky shore and sandy beach habitats are generally not particularly sensitive to disturbance and natural recovery typically occurs within 2-5 years. However, much of the Namaqualand coastline has been subjected to decades of disturbance by shore-based diamond mining operations (Penney et al. 2008). These cumulative impacts and the lack of biodiversity protection have resulted in many of the coastal habitat types in Namaqualand being assigned a threat status of ‘critically endangered’ (Lombard et al. 2004; Sink et al. 2012) (Table 3-10). Using the SANBI benthic and coastal habitat type GIS database (Figure 3-36 – Figure 3-38), the threat status of the benthic habitats within the mining licence areas, and those potentially affected by proposed mining, were identified.

Table 3-10: Ecosystem threat status for marine and coastal habitat types in PSJV’s Sea Concessions (adapted from Sink et al. 2011). Those habitats potentially affected by the cofferdam, diver-assisted and offshore mining are shaded.

No. Habitat Type Threat Status 1 Namaqua Exposed Rocky Coast Least Threatened 2 Namaqua Hard Inner Shelf Least Threatened 3 Namaqua Inshore Hard Grounds Critically Endangered 4 Namaqua Inshore Reef Critically Endangered 5 Namaqua Mixed Shore Endangered 6 Namaqua Muddy Inner Shelf Least Threatened 7 Namaqua Sandy Inner Shelf Least Threatened 8 Namaqua Sandy Inshore Critically Endangered 9 Namaqua Sheltered Rocky Coast Critically Endangered 10 Namaqua Very Exposed Rocky Coast Vulnerable 11 Southern Benguela Dissipative-Intermediate Sandy Coast Least Threatened 12 Southern Benguela Dissipative Sandy Coast Least Threatened 13 Southern Benguela Estuarine Shore Least Threatened 14 Southern Benguela Intermediate Sandy Coast Least Threatened 15 Southern Benguela Reflective Sandy Coast Least Threatened 16 Southern Benguela Sandy Outer Shelf Least Threatened

It must be pointed out that while the current and future cofferdam and offshore mining targets have been highlighted in Figures 36a-36c, numerous resource targets in Sea Concessions 1A

1 no-take means that extraction of any resources is prohibited.

Pisces Environmental Services (Pty) Ltd 77 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC have historically been mined, and will in future continue being mined, by vessel-based and shore-based diver-assisted operations. Diver-assisted operations in Sea Concession 1A have thus historically taken place, and will likely in future targeted diamond resources in Namaqua Inshore Hard Grounds, Namaqua Inshore Reef and Namaqua Sandy Inshore, all of which have been identified as critically endangered. Sea Concessions 2A, 3A, 4A and 4B have to date not been geophysically surveyed and consequently there are currently no future mining targets in these concession areas. Results from historical diver assisted explorations in 2A, 3A and 4A are limited and have at this stage not been taken forward as furture mining targets, although exploration and small-scale mining in these areas is likely to continue. Theoretically, however, unconsolidated sediments in bedrock features in all of these sea concessions could in future be targeted. Although mining operations would not directly target the critically endangered Namaqua Inshore Hard Grounds and Namaqua Inshore Reef, these habitats may be indirectly impacted by anchor damage and tailings disposal.

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Figure 3-36: Benthic and coastal habitat types in Sea Concessions 1A, 1B and 1C (Source data : SANBI). The habitats affected by the proposed cofferdam mining operations (red lines) and offshore mining operations (green shading) are identified in Table 3-10.

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Figure 3-37: Benthic and coastal habitat types in Sea Concessions 2A and 3A (Source data : SANBI). The habitats affected by the proposed cofferdam mining operations (red lines) and offshore remote mining operations (green circles) are identified in Table 3-10.

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Figure 3-38: Benthic and coastal habitat types in Sea Concessions 3A, 4A and 4B (Source data : SANBI). The habitats affected by the proposed cofferdam mining operations (red lines) and offshore remote mining operations (green circles) are identified in Table 3-10.

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4. LEGISLATIVE REQUIREMENTS Details of the legislative requirements are provided in Chapter 2 of the EMPR (Volume 1). What follows below is a brief summary of the key legislative requirements that the proposed mining activities must comply with.

4.1. National Legislation The key legislations include:  Minerals and Petroleum Resources Development Act (No. 28 of 2002);  National Environmental Management Act (No. 107 of 1998) (NEMA);  EIA Regulations 2014, as amended;  Regulations for the Control of Use of Vehicles in the Coastal Zone;  National Environmental Management: Air Quality Act (No. 39 of 2004) (NEM:AQA); and  National Environmental Management: Biodiversity Act, 2004 (No. 10 of 2004) (NEM:BA);  National Environmental Management: Protected Areas Act, 2003 (No. 57 of 2003);  National Environmental Management: Waste Act (No. 59 of 2008) (NEM:WA).  Marine Living Resources Act, 1998 (No. 18 of 1998);  National Environmental Management: Integrated Coastal Management Act, 2008 (No. 24 of 2008);

4.2. International Marine Pollution Conventions  International Convention for the Prevention of Pollution from Ships, 1973/1978 (MARPOL);  Amendment of the International Convention for the Prevention of Pollution from Ships, 1973/1978 (MARPOL) (Bulletin 567 – 2/08);  International Convention on Oil Pollution Preparedness, Response and Co-operation, 1990 (OPRC Convention);  United Nations Convention on Law of the Sea, 1982 (LOSC);  Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972 (the London Convention) and the 1996 Protocol (the Protocol);  International Convention relating to Intervention on the High Seas in case of Oil Pollution Casualties (1969) and Protocol on the Intervention on the High Seas in Cases of Marine Pollution by substances other than oil (1973);  Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal (1989); and  Convention on Biological Diversity (1992).

4.3. Other South African Legislation  Carriage of Goods by Sea Act, 1986 (No. 1 of 1986);  Dumping at Sea Control Act, 1980(No. 73 of 1980);

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 Hazardous Substances Act, 1983 and Regulations (No. 85 of 1983);  Marine Traffic Act, 1981 (No. 2 of 1981);  Marine Pollution (Control and Civil Liability) Act, 1981 (No. 6 of 1981);  Marine Pollution (Prevention of Pollution from Ships) Act, 1986 (No. 2 of 1986);  Marine Pollution (Intervention) Act, 1987 (No. 65 of 1987);  Maritime Safety Authority Act, 1998 (No. 5 of 1998);  Maritime Safety Authority Levies Act, 1998 (No. 6 of 1998);  Maritime Zones Act 1994 (No. 15 of 1994);  Merchant Shipping Act, 1951 (No. 57 of 1951);  National Environmental Management: Air Quality Act, 2004 (No. 39 of 2004);  National Environmental Management: Waste Act, 2008 (No. 59 of 2008);  National Heritage Resources Act, 1999 (No. 25 of 1999);  National Water Act, 1989 (No. 36 of 1998);  Occupational Health and Safety Act, 1993 (No. 85 of 1993);  Sea-Shore Act, 1935 (No. 21 of 1935);  Sea Birds and Seals Protection Act, 1973 (No. 46 of 1973);  Ship Registration Act, 1998 (No. 58 of 1998); and  Wreck and Salvage Act, 1995 (No. 94 of 1995).

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5. ASSESSMENT OF IMPACTS OF COASTAL AND OFFSHORE MINING ON MARINE FAUNA This chapter describes and assesses the significance of potential impacts related to the proposed prospecting and mining activities in PSJV’s mining licence areas. All impacts are assessed according to the rating scale defined in Section 1.2.2. Where appropriate, mitigation measures are proposed, which could ameliorate the negative impacts or enhance potential benefits, respectively. The significance of impacts with and without mitigation is assessed.

The identification and assessment of impacts relating specifically to the marine ecology cover the two main activity phases and unplanned activities, namely: 1 Prospecting activities, which include:  Geophysical surveys using sidescan sonar, sub-bottom profiling and multi-beam echosounding  Seabed sampling using megadrill and/or vibracorers and ‘walk-in’ platforms  Test mining using air-lift dredges, Wirth Drills and/or seabed crawlers 2 Mining activities, which include:  Shore-based, diver assisted suction pumps (“walpomp”)  Vessel-based, diver-assissted suction pumps  Cofferdam operations  Trenching using air-lift dredges and dredge pumps  Vertical mining using large-diameter drills  Horizontal mining using seabed crawlers 3 Unplanned Activities that may occur include:  Loss of equipment to the seafloor  Loss of fuel in the event of a vessel accident  Small instantaneous spills from vessels and machinery

5.1. Identification of Impacts Interaction of these activities with the receiving environment gives rise to a number of environmental aspects, which in turn may result in potential impacts. The identified aspects and their potential impacts are summarised below:  Physical disturbance and alteration of the supratidal, intertidal, shallow subtidal sandy and rocky habitats, and offshore unconsolidated sediments Supratidal:  Disturbance and alteration of supratidal habitats and loss of associated dune and coastal vegetation and biota through:  crushing and compacting by vehicles and heavy equipment, and  trampling by personnel  loss of terrestrial resources through illegal plant collection

Intertidal and shallow sub-tidal:  Disturbance and alteration of intertidal and shallow subtidal habitats and loss of associated benthic biota through:  blasting or mechanical clearing to locate heavy equipment close to the sea

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 re-location of boulders from target gullies  construction of cofferdam walls using terrestrially-sourced materials  removal of sediments  smothering by discarded coarse tailings  crushing by tractors, machinery and ‘walk-in’ platforms  trampling by mining personnel  cutting of kelp to facilitate movement of the suction hoses and airlines  loss of terrestrial and marine living resources through illegal plant collection, fishing, and gathering of intertidal organisms Deep water  Disturbance and loss of benthic biota and alteration of the seabed in deep water through removal of sediments during prospecting and sampling, vessel-based diver-assisted suction pump mining, trenching, and vertical and horizontal remote mining  Disturbance and alteration of offshore habitats and the associated communities through smothering by discarded tailings  Crushing of benthic biota during launching of the seabed crawler, removal of sediments, and anchor deployments and retrievals.  Accumulation of coarse tailings in the intertidal zone and on the seabed  Smothering of seabed habitat and associated benthic fauna  Reduced physiological functioning of marine organisms due to the biochemical effects on the water column and seabed sediments  Discharge of fine tailings from classifiers and on-board treatment plants  Increased water turbidity and reduced light penetration  Reduced physiological functioning of marine organisms due to the biochemical effects on the water column and seabed sediments  Increase in underwater and atmospheric noise levels by survey and mining vessels, and helicopters  Disturbance / behavioural changes of coastal and marine fauna  Avoidance of key feeding areas  Effects on key breeding areas (e.g. coastal birds and cetaceans)  Abandonment of nests (birds) and young (birds and seals)  Discharge of wastes to sea (e.g. deck and machinery space drainage, sewage and galley wastes) from survey and mining vessels, and local reduction in water quality  Reduced physiological functioning of marine organisms due to the biochemical effects on the water column and seabed sediments  Increased food source for marine fauna  Fish aggregation and increased predator-prey interactions  Localised reduction in water quality due to accidental release of fuel into the sea, discharge of fuel during bunkering and discharge of hydraulic fluid due to pipe rupture  Toxic effects on marine biota and reduced faunal health

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5.2. Project Controls A generic Environmental Code of Operational Practice (ECOP) has been developed for “walpomp” operations in the surf zone and shallow portions of Sea Concessions 1a, 2a and 3a (see Appendix 1 of main EIA report). Contractors are required to comply with the environmental specifications pertaining to:

 housekeeping;

 fuel and lubricant storage and management;

 refuelling;

 hydrocarbon contamination;

 solid waste management;

 oil spill procedure and reporting; and

 weekly monitoring.

5.3. Assessment of Impacts The impacts of marine diamond mining activities on marine benthic communities have been comprehensively investigated over the past 20 years thereby providing a good understanding of the potential impacts that might be expected from on-going activities. The identified environmental aspects and the related potential impacts are discussed and assessed below using information from the available literature.

5.3.1 Physical disturbance of benthic habitats By its very nature, prospecting for and mining of diamonds results in the physical disturbance of the shoreline and seabed. As the magnitude and extent of the disturbance is dependent both on the location of the target ores and the mining approach, these will be discussed separately below.

5.3.1.1 Disturbance and loss of supratidal2 habitats and associated biota The project activities that will physically disturb and alter supratidal habitat are described further below.

 Shore-based contractors operational in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A) typically establish tracks in the coastal zone to permit access to their mining areas by vehicles, tractors and heavy equipment.

 Campsites and caravans may be set up to provide on-site accommodation and shelter, thereby permitting longer operating times during periods of suitable weather.

 Poaching of marine resources and illegal collecting of succulents by mining personnel.

2 The supratidal zone lies above the mean high water spring tide mark and is only occasionally inundated by water during exceptional tides or by tides augmented by storm surges.

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 Mining infrastructure and equipment are often left on site following completion of mining operations in an area, or if the equipment becomes derelict. Impact description and assessment The impacts associated with mining activities in the coastal zone all result in severe scarring of the landscape, compaction of surface soils, destabilisation of dunes, disturbance and/or destruction of plant communities, and degradation of faunal communities dependant on the affected vegetation. Any biota present in the footprint of the campsite and high-shore mining area is likely to be crushed and trampled by vehicle activities and personnel.

The degree of impact associated with access tracks and mining camps depends on the scale of the mining activity and the type of terrain disturbed. Construction of camps, infrastructure and access routes results in localised removal of vegetation, which can potentially lead to soil erosion and removal of topsoil and its associated plant seed bank depending on where the camps, infrastructure and access routes are located. While actively forming soils tend to support rugged pioneer plant communities, which are typically dynamic and resilient to disturbances, older, more stable soils harbour established terrestrial plant communities more sensitive to disturbance of the soil equilibrium. Such plant communities and their dependent fauna usually only recover over the long term following disturbance of the soil equilibrium. The indiscriminate storage of mining equipment and vehicles, the location of camps and vehicle parking areas, and proliferation of informal tracks can also damage vegetation and lead to compaction of soil and uncontained erosion of access roads, thus hampering the re- establishment of vegetation. Where access roads to mining sites traverse dunes, the crushing and destruction of dune vegetation can affect dune stability and dynamics, potentially leading to wind erosion and the creation of blow-outs. The fore-dune area (the small sparsely vegetated dunes just above the drift line) in particular, is the most sensitive part of the littoral active zone as it serves as a transition zone between the physically and biologically different terrestrial habitats, and surf zone processes (Brown & McLachlan 2002). As such, individual beaches may develop specific characteristics, resulting from local physical conditions, and the resultant faunal and floral communities are adapted to these specific characteristics.

Poaching of wild life and marine resources, and illegal succulent collecting by mining personnel have also been identified as major threats to the coastal flora and fauna (Newton & Chan 1998; Burke & Raimondo 2002). Mining infrastructure and discarded equipment left on site also hinders recovery of the arid terrestrial ecosystems, as well as resulting in severe aesthetic impacts.

Impacts associated with the disturbance of supratidal habitats would be of high intensity, but remain localised around each contractor site. However, as informal tracks and contractor campsites have been established throughout the surf zone concessions, the extent can be considered regional. Due to the sensitivity of the coastal habitats to disturbance, impacts would persist over the medium- to long term and be only partially reversible. The likelihood of impacts to coastal vegetation and biota is highly probable and any adverse effects on coastal biota are considered of HIGH significance without mitigation and MEDIUM significance with mitigation.

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Mitigation The following mitigation measures are proposed:

 Prepare site-specific ECOPs for each contractor and each allocated mining block. The ECOP should include specific details for the following aspects:

 Environmental considerations (i.e. identification of sensitive receptors) and establishment of no-go / restricted areas  Access route(s) to allocated mining block  Extent of mining block and demarcation of the campsite and processing area(s), and refuelling / maintenance areas  Housing keeping:  Use of drip trays under stationary plant and for refuelling and maintenance activities  Use and maintenance of toilet facilities  Bunding of fuel stores  Demarcation of refuelling and maintenance areas  Waste management, including the removal of all facilities, waste and other features established during mining activities  Rehabilitation specification (if necessary), e.g. topsoil management, reshaping, netting, etc.  Establishment of a rehabilitation fund  Monitoring  Use only established tracks and roads, as far as possible, to access allocated concession blocks in order to avoid the creation of new tracks. When mining moves along the coast within a concession block and no tracks or roads exist parallel to the coast, access should be undertaken below the HWM when on sandy / beach areas.

 Identify and map the required existing tracks and develop a maintenance and rehabilitation program that ensures that necessary tracks are maintained. Permitted tracks are to be marked as such and all duplicate tracks leading to mining sites should be closed and rehabilitated.

 Avoid the establishment of processing areas or camps within 100 m of the edge of a river channel or estuary mouth.

 Locate processing areas or camps, as far as possible in previously disturbed areas or areas of least sensitivity.

 Limit the processing area and campsite to the minimum reasonably required and to that which will cause least disturbance to the vegetation and natural environment. The extent of the sites should be clearly demarcated (e.g. with droppers).

 Do not collect any plants within the mining area

 Undertake Environmental Awareness Training to ensure mining personnel are appropriately informed of the purpose and requirements of the EMPr and ECOP.

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 Before the commencement of any work on site, the contractor's site staff must attend an environmental awareness-training course presented by the Environmental Manager/Officer. The contractor must keep records of all environmental training sessions, including names of attendees, dates of their attendance and the information presented to them.

 Prior to a contractor leaving a site and/or moving to a new site, the area must be audited by the Environmental Manager/Officer. Only once the Environmental Manager/Officer is satisfied that the area has been suitably cleaned and rehabilitated should the rehabilitations funds be paid back to the contractor.

Destruction and loss of coastal vegetation and biota

Without Mitigation Assuming Mitigation Extent Regional: full extent of surf zone Regional concessions Duration Medium- to Long-term Medium-term Intensity High Medium Probability Probable Probable Confidence High High Status Negative Negative Significance High Medium

Reversibility Partially reversible Mitigation Potential Low

5.3.1.2 Disturbance and loss of intertidal and shallow subtidal habitats and associated biota The project activities that will physically disturb and alter the intertidal and shallow subtidal beach and rocky shore habitats are described further below:

 “Walpomp”: The mining targets for shore-based, diver-assisted operations in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A) are located in bedrock features, gullies and small sandy bays below the low water mark and to depths of ~5 m.

 To access these deposits, shore contractors usually locate the heavy pumping and sorting equipment as close to the sea as possible, to minimise suction-hose lengths and pumping pressure gradients. This typically involves driving in and physical damage to the supratidal and intertidal zone, and may require blasting or mechanical damage in the rocky supratidal and intertidal regions to facilitate access to the low shore.

 To access the deeper gravel deposits in potholes and gullies, large rocks and boulders may need to be moved by divers with crowbars, or dragged from the gully at low tide by tractor and chains to be deposited at higher tidal levels.

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 To facilitate movement of the suction hoses and airlines in the surf zone and beyond, divers may cut kelp.

 Divers guide the pump nozzles into the unconsolidated sediments in small sandy bays or rocky gullies, to remove sandy overburden and retrieve the target gravels, together with the associated benthic infauna and epifauna.

 The sediments are pumped ashore where they are sorted in a classifier through a series of rotary screens. Oversize tailings (>20 mm) accumulate around the screening units and fines (<1.6 mm) are returned to the sea across the intertidal regions as a sediment slurry.

 Diamond divers operating from the shore may purposefully target rock lobsters for consumption purposes, although compared to the annual quota landed by the commercial rock lobster industry the quantities poached on the few diving days per month are insignificant.

 Jack-up platforms: Sampling and mining operations in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A) by ‘walk-in’ jack-up platforms are being considered as an option for the intertidal and surf zone regions of sandy beaches, which have thus far been mostly inaccessible to mining.

 The platforms would be fitted with primary and secondary sampling tools comprising jet pumps (for rapid overburden removal) and suction tubes (to extract gravels from bedrock crevices) and a screening plant.

 Overburden and marine sands are de-watered and screened on the platform, with the oversize material (>25 mm) and fines (<1.4 mm) being disposed of back into the sea where they are rapidly redistributed by wave action.

 Cofferdams: Mining targets for cofferdam operations in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A) are similarly located in bedrock features underlying modern beach sands, extending through the intertidal zone into the immediate nearshore subtidal areas. The diamondiferous deposits are sequentially mined within the confines of an extensive seawall constructed from substantial volumes of rocks, boulders and gravel relocated from inland sources, and overburden stripped from the mining block. The seawall is constantly maintained while the impounded area is pumped dry and the target gravels are extracted by bucket-shovel, and stockpiled before being fed into a feed-hopper/classifier. Once a section within a mining block has been mined to completion, the seawall is moved progressively seaward until it can no longer withstand the wave forces. The use of non-native material for the construction of cofferdam walls on both beach and rocky shorelines significantly changes the nature of the original shoreline.

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Impact description and assessment

Shore-based diver operations (“walpomp”) On rocky shores targeted by shore-based diver units, intertidal and subtidal organisms are damaged or destroyed by mining activities in a number of ways. Where access to the low water mark is achieved by blasting or mechanical damage to the shore, supratidal and intertidal benthic biota in the disturbance footprint would be disturbed or crushed by the movement of mining equipment, or would be completely eliminated. Similarly, during the removal and relocation of boulders from subtidal gullies into the intertidal zone, the benthic biota associated with the boulders would be killed, and other benthos may be indirectly dislodged or crushed by the tractors, chains and by the boulders themselves. Macrofauna within the sediments being pumped ashore would be disturbed, damaged or killed. If the classifier is located below the high water mark during mining, any intertidal biota in the footprint of the tailings heap accumulated around the classifier would be smothered and crushed. Scouring of intertidal organisms in the path of the discharged fine-tailings slurry may also occur and the general activities of the contractors around the classifier would result in trampling and crushing of some biota.

Coarse tailings that accumulate around classifiers located in the intertidal area below the high water mark will be redistributed by wave action over the short- to medium term, and during this redistribution process scouring of existing communities is likely to occur. If deposited above the high water mark, redistribution would not occur and the sterile tailings heaps would persist over the long term (see Figure 5-1).

Figure 5-1: Classifier located above the high water mark, with tailings heaps accumulated in the supratidal.

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Studies conducted in other parts of the world have shown that high intensity trampling on rocky shores can result in the removal of most of the intertidal assemblages, although the effects are dependent on the community present, with foliose algae (particularly fucoid species) being more susceptible than algal turfs, and barnacles more susceptible than dense patches of mussels (Povey & Keough 1991; Brosnan & Crumrine 1994; Schiel & Taylor 1999). While the damage to and physical alteration of the rocky intertidal shoreline in ways that cannot be remediated by swell action and can be more or less permanent (e.g. the deposition of large piles of pebbles and boulders, or blasting of intertidal rocks), re-establishment of rocky intertidal and subtidal communities on available hard substratum is relatively rapid (2-5 years) once persistent disturbances have ceased.

The cutting of kelp to facilitate movement of the suction hoses and airlines, has a localised impact on the kelp bed community, the severity and duration of which depends on the extent of kelp cut, the frequency and method of kelp cutting and the age of the kelp. Monitoring has found that the harvesting of whole plants of Ecklonia maxima increases light penetration into the sub-canopy resulting in the development of a highly diverse understorey algal community, which predominated for at least 12 months before kelp sporelings can recruit. No effect on the associated faunal species diversity has been established, however (Simons & Jarman 1981; Kennelly 1987a, 1987b; Christie et al. 1998; Levitt et al. 2002). A similar increase in floral diversity, particularly of red and green foliose algae was reported in newly cleared Laminaria beds, although these macroalgae did not persist for long and were soon out-competed by high densities of recruiting Laminaria sporelings (Pisces Environmental Services 2007).

Although recovery following kelp cutting is in most cases rapid (Christie et al. 1998; Levitt et al. 2002; Pisces Environmental Services 2007), long-term changes in kelp forest communities in response to various disturbances have been documented (Dayton et al. 1992), with disturbance potentially causing many lag-effects including the outbreak of understory algae (see also Foster 1975), the availability of, and intraspecific competition for primary space on the substratum, and changes in grazing patterns of herbivores. Some species of sea urchins feed preferentially on kelp sporelings, and in sufficient densities can keep an area entirely denuded of kelp (Keats et al. 1984; Chapman & Johnson 1990; Dayton et al. 1992; Steneck et al. 2002). The urchin Parechinus angulosus common off the southern African west coast, however, feeds on drift- algae (Day & Branch 2002), and would thus have no effect on the recovery of southern African kelp beds (see also Levitt et al. 2002). Holdfasts of adult kelp plants also play an important role as kelp sporelings settle most successfully at or near these holdfasts, which provide shelter from grazing (Anderson et al. 1997). A clear-cut area or repeatedly cut area will therefore recover more slowly than an area where only adults are cut and small kelp plants are left behind. On the West Coast, kelp beds have a sheltering effect on the otherwise exposed coastline. Recovery of cut kelp beds can occur within two years (Parkins & Branch 1996; Anderson 2000; Levitt et al. 2002; Pisces 2007), but in some areas extensive and repeated kelp cutting by diamond divers has resulted in kelp bed habitats being locally eliminated and replaced by extensive stands of mussels (Engeldow & Bolton 1994), or colonies of the Cape reef worm Gunnarea gaimardi (G. Koeglenberg & Q. Snethlage, diamond divers, pers. comm.). As a consequence, wave exposure in the affected areas changed from sheltered to semi-exposed, with concomitant changes in intertidal and shallow subtidal community structure. Kelp beds

Pisces Environmental Services (Pty) Ltd 92 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC providing shelter for a wide diversity of marine flora and fauna (Field et al. 1980), and in the central and southern Benguela region are known to serve as an essential nursery area for rock lobster and several fish species (Velimirov et al. 1977; Velimirov & Griffiths 1979; Carr 1989, 1994). Although adult kelp plants can survive sand inundation for some time, kelp sporelings are unable to settle and re-establish in sediment-influenced nearshore areas due to scouring and reduced light penetration. Extensive and repeated cutting of kelp by diamond-divers, in combination with increased sediment mobilisation and deposition as a result of coastal mining operations, can therefore potentially affect the sustainability of kelp beds in the mining areas. Reduction or loss of kelp beds may in turn have knock-on effects on recruitment success of rock lobsters in the shallow nearshore areas through reduction of suitable habitat and food sources, with important implications for the success of the harvest of this commercially important resource. Kelp-cutting is practiced on a small-scale and under limited circumstances only by diamond divers, and kelp recovery rates appear to exceed the frequency of cutting, in all except the most frequently dived areas (G. Koeglenberg & Q. Snethlage, diamond divers, pers. comm.). At current levels, the impacts associated with kelp-cutting can therefore be considered insignificant. However, if the number of shore-based operations increases in the future, the impact of kelp cutting, in combination with increased mining-induced sedimentation, is likely to increase in significance.

Poaching and incidental pumping of rock lobster by mining personnel has also been identified as a threat to the severely depleted rock lobster resource in Namaqualand (Barkai and Bergh 1992). However, compared to the annual quota landed by the commercial rock lobster industry the quantities poached on the few diving days per month are insignificant.

Impacts associated with the cumulative disturbance of rocky intertidal and shallow subtidal habitats by shore-based diver operations would be of medium intensity. Where shore-based operations are undertaken in the Namaqua Sheltered Rocky Coast and Namaqua Mixed Shore habitats in Sea Concession 3A and 4A (see Habitat Type 5 and 9 in Figures 36a-c), which have been identified as critically endangered and endangered, respectively (Sink et al. 2011), impacts can be considered of high intensity. Although impacts would be limited to a scale of a few 10s of metres around each individual operation, as shore-based diver operations have been established throughout the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A in Licence 554MRC, the extent can be considered regional. Impacts to the rocky intertidal and shallow subtidal biota would persist over the short to medium term and be fully reversible, except for critically endangered habitats where impacts may be only partially reversible. The natural redistribution by wave action of tailings heaps discarded on the high shore may, however, only occur over the medium-term. The likelihood of impacts to the rocky intertidal and shallow subtidal biota by shore-units is definite and any adverse effects are considered of MEDIUM to HIGH significance without mitigation, reducing to VERY LOW significance if mitigation measures are imposed. For shore-based diver operations mining sandy bays off beaches, impacts on macrofaunal communities would likewise be of medium intensity but these would persist over the very short term only and be fully reversible. The impacts would be highly localised for individual operations but as they extend throughout the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A in Licence 554MRC, the extent can be considered regional. The likelihood of impacts to sandy intertidal and shallow subtidal

Pisces Environmental Services (Pty) Ltd 93 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC macrofauna by shore-based diver operations is probable and any adverse effects are considered of LOW significance without mitigation and VERY LOW significance with mitigation.

Destruction and loss of rocky intertidal and shallow subtidal biota by shore-based diver operations Without Mitigation Assuming Mitigation Extent Regional: full extent of surf zone Regional concessions Duration Short- to Medium-term Short-term Intensity Medium to High (critically Low endangered habitats) Probability Definite Probable Confidence High High Status Negative Negative Significance Medium to High (critically Very Low endangered habitats)

Reversibility Fully reversible – Partially reversible (critically endangered habitats) Mitigation Potential High

Destruction and loss of sandy intertidal and shallow subtidal sandy beach macrofauna by shore-based diver operations Without Mitigation Assuming Mitigation Extent Regional: full extent of surf zone Regional concessions Duration Short-term Short-term Intensity Medium Low Probability Probable Probable Confidence High High Status Negative Negative Significance Low Very Low

Reversibility Fully reversible Mitigation Potential High

‘Walk-in’ platforms These sampling and mining tools would primarily be implemented in the surf zone of sandy beaches and shallow sandy bays, none of which have been identified as endangered or critically endangered (Sink et al. 2011). Thus the fauna and flora associated with rocky substrates are unlikely to be affected. Invertebrate macrofauna living in or on the unconsolidated sediments being pumped onto the ‘walk-in’ platforms would be disturbed, damaged or killed, and those within the footprint of the platform legs would be crushed. Tailings discarded back into the sea from the platforms would smother invertebrate epifauna and infauna in the surf zone sediments (see section 5.3.2).

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While the intertidal area of sandy beaches is characterised by a relatively rich fauna, species abundance typically declines substantially in the surf zone reaching a minimum at the breakpoint of the waves. Impacts on macrofaunal communities living in the unconsolidated surf zone sediments would thus be comparatively low. Furthermore, the communities inhabiting this naturally highly dynamic environment are inherently robust and habituated to natural disturbances. On a high-energy coastline, such as in the study area, the recovery of the physical characteristics of intertidal and shallow subtidal unconsolidated sediments to their pre-disturbance state following sampling / mining by ‘walk-in’ platforms can occur within a few tidal cycles under heavy swell conditions, and will typically result in subsequent rapid recovery of the invertebrate epifaunal and infaunal communities to their previous state.

Impacts associated with the disturbance of intertidal and shallow subtidal unconsolidated habitats by ‘walk-in’ platforms would be of medium intensity. Should these ‘walk-in’ mining units be implemented, they are likely to operate in only a few suitable bays within Sea Concessions 1A, 2A and 3A and any impacts would thus remain localised. Impacts to the biota would persist over the short term and be fully reversible. The likelihood of impacts to intertidal and shallow subtidal biota by ‘walk-in’ platforms is probable and any adverse effects are considered of VERY LOW significance both without and with mitigation.

Destruction and loss of intertidal and shallow subtidal macrofauna by ‘walk-in’ platforms

Without Mitigation Assuming Mitigation Extent Local: limited to mining area Local Duration Short-term Short-term Intensity Medium Low Probability Probable Probable Confidence High High Status Negative Negative Significance Very Low Very Low

Reversibility Fully reversible Mitigation Potential Low

Cofferdams The building of cofferdam walls on either sandy or rocky shores effectively smothers and eliminates any supratidal, intertidal and subtidal biota in the footprint of the cofferdam and the target mining block. By introducing large volumes of non-native material into the intertidal zone, the nature of the intertidal area is completely altered thereby resulting in substantial shifts in benthic community structure, with potential knock-on effects on higher order consumers who rely on the intertidal organisms as a food source. Indirect impacts due to redistribution of sediments eroded from the seawall would include scouring and smothering of biota in adjacent areas. Further indirect impacts may include changes in long-shore wave patterns resulting in increased erosion of the beaches down current (to the north) of the cofferdams. Assuming all non-native material used for dam wall construction is removed at the end of operations, this effect is likely to persist only for as long as the cofferdam walls are left

Pisces Environmental Services (Pty) Ltd 95 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC in place and for some time afterwards, until the beach profiles and shorelines regain equilibrium. If large rocks and rock berms are left in place, residual impacts are likely to remain. Although the impacts of cofferdams remain localised by definition, impacts can extend many 100s of metres along-shore and up to 300 m offshore. The impacts of a single cofferdam operation is therefore far more extensive than that of a diver-assisted shore unit or a ‘walk-in’ platform.

On a high-energy coastline the recovery of the physical characteristics of intertidal and shallow subtidal unconsolidated sediments to their pre-disturbance state following localised cofferdam operations that do not use rocks to stabilise the cofferdam walls, can occur within a few tidal cycles under heavy swell conditions, and will typically result in subsequent rapid recovery of the invertebrate epifaunal and infaunal communities to their previous state. Previous studies on the impact of cofferdam and larger-scale seawall mining on macrofaunal beach communities identified that the physical state of beaches on the West Coast is entirely driven by natural conditions, and is not affected (except during actual mining) by beach mining operations in the medium- to long-term (Pulfrich et al. 2004; Pulfrich et al. 2015). Removal of beach sands and subsequent extraction of target gravels results in a significant, yet localised and short-term decrease in macrofaunal abundance and biomass. Intertidal beach macrofauna appear to be relatively tolerant to disturbance, and re-colonization of disturbed areas is rapid (van der Merwe & van der Merwe 1991; Brown & Odendaal 1994; Peterson et al. 2000; Schoeman et al. 2000; Seiderer & Newell 2000; Nel et al. 2003). Impacted areas are initially colonized by small, abundant and opportunistic pioneer species with fast breeding responses to tolerable conditions (e.g. crustaceans and polychaetes). If the surface sediment is similar to the original surface material when mining operations cease, and if the final long-term beach profile has similar contours to the original profile, the addition or removal of layers of sand and gravel does not have enduring adverse effects on the sandy beach benthos (Hurme & Pullen 1988; Nel & Pulfrich 2002; Nel et al. 2003). However, the deposition of large volumes of non-native rock during seawall construction may result in the physical alteration of the shoreline to an extent that cannot be remediated by swell action. While the rock material may become covered with sand over time as it settles into the beach sediments, the sediment profile may be permanently altered, with potential effects on the associated macrofaunal communities. In extreme cases, where the cofferdam wall material is not completely removed, stretches of sandy beach could be permanently transformed into mixed and rocky shore habitats, with concomitant changes in the associated benthic biota (see Figure 5-2 below).

The impacts associated with the disturbance of intertidal and shallow subtidal habitats by cofferdam operations would be of high intensity, regardless of the SANBI benthic habitat classification, and remain relatively localised around each mining block. However, considering the number of mining targets identified for cofferdam operations in Licence 554MRC, the extent of the impact can be deemed regional. If the cofferdam is constructed in rocky intertidal habitats, impacts to the biota originally present on the shoreline would persist over the medium- to long term and be only partially reversible. Establishment of alternative communities in the altered habitat would, however, occur over the short-term. In contrast, if the cofferdam is constructed along a sandy coastline, impacts to beach macrofauna would persist only over the medium term and be fully reversible. Although the PSJV require contractors to remove rock, as far as possible, after mining, if rocks remain on the beach these

Pisces Environmental Services (Pty) Ltd 96 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC would potentially persist over the long term and impacts would be only partially reversible. The likelihood of impacts to intertidal and shallow subtidal biota by cofferdams is definite and adverse effects are considered of VERY HIGH significance without mitigation in the case of operations on rocky shores and HIGH significance without mitigation for operations on sandy beaches. Residual impacts remaining after mitigation would be of MEDIUM significance in the case of beaches and HIGH significance for rocky shores.

Figure 5-2: Non-native rocky material used to construct cofferdam walls on an otherwise sandy shore.

Destruction and loss of intertidal and shallow subtidal biota by cofferdam operations

Without Mitigation Assuming Mitigation Extent Regional: full extent of surf zone Regional concessions Duration Medium- (beaches) to Long-term Medium- to Long-term (rocky shores) Intensity High Medium Probability Definite Definite Confidence High Medium Status Negative Negative Significance High (beaches) to Very High (rocky Medium (beaches) to High (rocky shores) shores

Reversibility Partially reversible Mitigation Potential Low

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Mitigation The following mitigation measures are proposed:

General

 Mining of any nature should not be permitted in intertidal and shallow subtidal habitats identified as endangered Namaqua Mixed Shore (coffer dam mining only) or critically endangered Namaqua Sheltered Rocky Coast (all mining methods) by the SANBI’s National Biodiversity Assessment (Sink et al. 2011). If, however, prospecting / mining is proposed within these areas an independent assessment of the habitats and associated biota should be undertaken by a suitably qualified ecologist to verify the habitat status. Should it be confirmed that the habitats are indeed ecologically unique, these areas should be declared ‘no-go’ areas and any future prospecting / mining there should be prohibited.

 Restrict mining within the endangered Namaqua Mixed Shore habitat (for driver assisted mining and mobile pump unit operations), which is represented by more extensive areas off the West Coast, to less than 1% of the available habitat within the mining licence area annually, unless the habitat is confirmed to be different by a suitably qualified ecologist.

 An Environmental Code of Operational Practice (ECOP) must be prepared for each contractor (refer to Section 5.3.1.1 for the contents thereof).

 Do not collect any shellfish (including abalone, rock lobster, mussels) or undertake recreational or subsistence fishing within the mining area.

 Prior to a contractor leaving a site and/or moving to a new site, the area must be audited by the Environmental Manager/Officer. Only once the Environmental Manager/Officer is satisfied that the area has been suitably cleaned and rehabilitated, tailings dumps and cofferdam walls have been removed, and area reshaped back to natural topography should the rehabilitations funds be paid back to the contractor.

Shore-based diver operations

 Prohibit blasting of rocky intertidal habitats and investigate alternative options to create the required access to the low water mark.

 Limit the removal of boulder by tractor and chains. If re-location of boulders is necessary these should not be removed to higher tidal levels, or accumulated in rock piles.

 During diver operations, classifiers used by shore-based contractors must be located as far down the intertidal zone as possible to facilitate the natural redistribution of coarse tailings by wave action, but definitely below the high water mark. If tailings stockpiles have been or are created on the high shore, the material must be removed on a regular basis and re-used for other applications (e.g. dust control around buildings and processing plants, construction of cofferdams).

 Divers should avoid removing and/or damaging rock lobsters when operating suction pipes during mining.

 Minimise kelp cutting unless diver safety is at stake, or it is essential for the operation.

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 Where kelp cutting is deemed necessary, avoid removing the entire plant by cutting the kelp stipes just above the holdfast.

 Monitoring: Undertake a once-off survey of intertidal rocky shores in the licence area to determine the species diversity, percentage cover and abundance of benthic macrofauna and macroalgae, to investigate the relationship of benthic community structure with time since mining. Details are provided in the monitoring plan. A follow-up survey undertaken five years after the initial survey should also be considered.

‘Walk-in’ platforms

 Operate ‘walk-in’ platforms in sandy bays only to avoid damage of shallow water reefs and their associated kelp-bed communities. (This is primarily an operational constraint due to the difficulty of controlling stable leg positions in uneven rocky terrain).

Cofferdams

 The Environmental Manager/Officer must meet with all contractors on-site prior to mining in order to obtain an understanding of the mining approach and the local environmental sensitivities; after which a project-specific ECOP should be compiled for the mining operations.

 Limit the number of cofferdams operational concurrently. Mine each block sequentially to completion, with only two adjacent blocks active concurrently.

 Use materials sourced locally from old tailings dumps for cofferdam construction and avoid using quarried material where possible.

 As soon as a block has been mined out, remove cofferdam material from the beach as far as wave action will allow and re-use this material during further construction. For cofferdams located on rocky shores, remove cofferdam material as far as possible from gullies and potholes. Monitoring:

 Monitor sand accumulation or erosion from the southern and northern limits of individual cofferdams by measuring the beach profiles on a monthly basis. Profiles should be measured at low spring tide.

 To quantify the impact of cofferdam mining on intertidal communities and determine recovery rates of the affected biota on cessation of mining, undertake a monitoring programme of intertidal sandy beaches in the licence area adopting a before-after/control-impact (BACI) sampling approach that provides spatial replication within each habitat and temporal replication at different times after mining. Details are provided in the monitoring plan (see Section 7).

 If the BACI approach is not possible (i.e. control sites cannot remain undisturbed for the duration of the monitoring programme), then sample at unmined, currently mined and historically mined sites throughout the licence area to investigate the relationship of invertebrate macrofaunal communities with time since mining. Details are provided in the monitoring plan (see Section 7).

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 The monitoring programme should be used to confirm the significance of the residual impacts and, depending on the results, used to inform future mine planning and methods.

5.3.1.3 Physical disturbance of the seabed during prospecting and mining operations in deeper waters The project activities that will physically disturb and alter seabed habitats are described further below:

 Small vessel-based diver-mining contractors operating in Licence 554MRC (Sea Concession 1A, 2A and 3A) and Licence 512MRC (Sea Concession 4A), usually target gravel-filled gullies and bedrock features in 5 - 12 m depth (but up to 17 m if an onboard decompression chamber is available), using suction nozzles to suck up and deliver overburden sands and target gravels directly to an onboard classifier. During the mining process, large boulders may be exposed or shifted by divers to access deeper gravel layers in gullies and potholes, and these may be accumulated into underwater rock piles. Fine material from the classifier washes directly back into the sea whilst the oversize fraction (>20 mm) is discharged directly overboard. Some vessels are fitted with ‘blower’ cowlings, which direct the thrust of the propeller downwards to displace the overlying fine sediments, exposing the deeper gravel deposits. These sands are rapidly returned into the temporary excavations due to swell action.

 During prospecting and sampling activities in Licence 554MRC (the deeper portions of Sea Concession 1A, 2A, 3A and 1B), Licence 512MRC (the deeper portions of Sea Concession 4A), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C), sampling and mining tools (vibrocorers, dropcore, air-lift dredges and dredge pumps, large-diameter drill or seabed crawler) would be used to obtain samples of unconsolidated seabed sediments to the depth of the clay/rock footwall. The excavated sediments would be air-lifted or pumped onto the vessel where they are screened, classified and sorted, with all fines, oversize and screened waste-gravel being returned directly to the sea. Note: dredge pump operations are restricted to water depths of ± 12 to 30 m. Airlift and crawler operations work to a minimum depth of ± 30 m.

 Test-mining (bulk sampling) and mining in Licence 554MRC (Sea Concession 1B), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C), would involve the removal of unconsolidated seabed sediments using dredge pump, airlift systems, large-diameter drills or seabed crawlers. Dredge pump and airlift dredging systems can excavate up to 3 m of unconsolidated sediments from the seabed, using one to two passes. The excavated trench is typically 10 m long by 1.6 m wide. Airlift vessels typically operate two mining tools in parallel. Rocks and boulders rejected by the primary sorting bars at the entrance of the suction head remain on the mined footwall. All excavated sediments are brought to the surface using airlifts or pumps, where they are screened, classified and sorted, with fines, oversize and screened waste-gravel being returned directly to the sea.

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 The drill-head of large-diameter drills comprise a circular disc fitted with wheel cutters and hardened steel scrapers, which is lowered vertically to the seabed on an extendable ‘drill string’. The drill can penetrate about 2 - 3 m of sediment and partially consolidated conglomerate or calcareous sandstone in water depths down to 150 m. Sediments are excavated in a systematic pattern of overlapping circles in the 50m x 50 m mining block. Rocks and boulders rejected by the primary sorting bars at the entrance of drill string remain on the mined footwall. Loosened rocks and sediment are pumped to the surface through the drill string for onboard processing with fines, oversize and screened waste-gravel being returned directly to the sea. Test-mining and mining using a vertical approach would potentially be undertaken at water depths of >30 – 180 m in Licence 554MRC (Sea Concession 1B), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C).

 Seabed crawlers consist of an underwater vehicle mounted on twin caterpillar tracks, which is lowered to the seabed on a hoist rope, with power and signal umbilical cables and an articulated arm with integrated suction hose. Seabed crawlers usually mine by systematically advancing along a ‘lane’, thereby achieving precise and complete coverage of the area to be mined. The crawler is fitted with an anterior suction system powered by a submersible dredge pump, which provides high suction power at the mining face. The suction head is also equipped with water jets to loosen seabed sediments, while cutters break up harder material and assist in excavation, and suction-nozzle mounted sorting bars filter out oversize boulders. The anterior suction arms operate by either a vertical radial (digging) motion, or through a horizontal sweeping action in a swathe of up to 22 m width. Crawlers are capable of mining sediment thicknesses of up to ~5 m, in water depths of >30 m to 180 m. Rocks and boulders rejected by the primary sorting bars at the entrance of the suction head remain on the mined footwall. Excavated sediment are pumped to the surface through the suction hose for onboard processing with fines, oversize and screened waste-gravel being returned directly to the sea. Test-mining (bulk sampling) and mining using a seabed crawler would potentially be undertaken in the deeper portions of Licence 554MRC (Sea Concession 1B), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C).

Impact description and assessment

Vessel-based diver operations Diver-assisted mining at depths <17 m specifically targets gravel areas, which are naturally barren or sparsely inhabited by infauna or commercially important species such as rock lobsters. The removal of unconsolidated sediments from bedrock features during mining will result in the disturbance and loss of benthic macrofauna inhabiting the unconsolidated sediments. Such effects are largely confined to the mined gully and therefore highly localised, and benthic communities and rock lobsters within metres of the edge of the impacted gullies remain unaffected by the mining-induced disturbance.

By removing the overlying gravel, mining exposes expanses of previously embedded boulders. Initially, these newly exposed boulder areas are uninhabited, and clearly distinguishable (in

Pisces Environmental Services (Pty) Ltd 101 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC terms of benthic community) from unmined areas. However, the exposed boulders and rock become gradually colonized by crustose coralline algae, encrusting sponges, hydroids and anemones, and within a year the taxonomic diversity of boulder beds exposed by mining resembles adjacent unmined reef areas (Barkai & Bergh 1992; Parkins & Branch 1995, 1996, 1997; Pulfrich 1998a, 1998b, 2004a; Pulfrich & Penney 2001; Pulfrich et al. 2003c). By removing gravels and exposing hard substratum, these shallow-water mining operations thus increase the biodiversity on previously buried and uninhabited rocky surfaces. The structure of the developing communities (species composition) on the boulder-fields, however, remains distinguishable from adjacent unmined reef communities, due primarily to the difference in physical characteristics of boulder beds and reefs, and the resultant natural differences in benthic communities on these seabed types. By exposing highly structured habitat, diver- assisted mining also appears to create suitable habitat for rock lobsters. However, as near- bottom sediment transport within the wave base is primarily swell-driven, the excavated gullies and potholes are filled in by mobilised sediments over the short-term, with lobsters moving out of the gullies and back onto the adjacent reef.

Garnett & Ellis (1995) and Jewett (1999), who investigated the potential impacts of a marine placer dredge mining operation on populations of the commercially exploited red king crab (Paralithodes camtschatica) in the north-eastern Bering Sea (Alaska), likewise concluded that dredging operations did not significantly affect crab populations. They found no differences in migration, feeding behaviour, crab sex and size composition and commercial catches of crabs between dredged and undredged sites, despite it taking up to three years for recolonisation of the dredge footprint by benthos to attain numerical values close to those at control sites.

The impacts associated with the removal of seabed sediments and their associated biota by vessel-based diver operations would be of high intensity, but remain relatively localised within each mining target. However, considering the number of vessels operational in the A- concessions, the extent of the impact can be deemed regional. As infill rates in the dynamic wave-base is rapid, impacts to the biota originally present in the sediments would persist over the short-term and would be fully reversible. If critically endangered (Namaqua inshore hard grounds, Namaqua inshore reefs, Namaqua sandy inshore) or endangered habitats (Namaqua mixed shore – See Figures 36 - 38) are affected, which cumulatively include large areas of Sea Concession A and B, impacts to the biota may persist over the medium-term and be only partially reversible. Establishment of alternative communities in the altered habitat would, however, occur over the short-term. The likelihood of impacts to invertebrate macrofauna by vessel-based diver-assisted mining is definite and adverse effects are considered of MEDIUM to HIGH significance without mitigation, reducing to LOW significance with mitigation.

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Disturbance and loss of nearshore biota by diver-assisted operations

Without Mitigation Assuming Mitigation Extent Regional: full extent of surf zone Regional concessions Duration Short- to Medium-term (critically Short -term endangered habitats) Intensity High Medium Probability Definite Probable Confidence High High Status Negative Negative Significance Medium to High (critically Low endangered habitats)

Reversibility Partially (critically endangered habitats) to Fully (nearshore) reversible Mitigation Potential Low to Medium

Remote mining operations Deep-water mining operations similarly specifically target areas of unconsolidated sediments and gravels, avoiding areas of hard ground and reefs. In Concession 1A mineable sediment areas comprise 48.3% of the total concession area, whereas in Concession 1B and 1 C the mineable area comprises 48.5% and 0.96%, respectively3. Sands and muds provide a favourable substratum for invertebrate macrofauna, but gravels tend to be naturally barren or sparsely inhabited by infauna, particularly in the wave-based regime. Regardless of the mining approach, the removal of unconsolidated sediments during mining will result in the disturbance and loss of macrofauna living on and within the sediments. Research conducted over the last few decades has shown that sediment removal due to offshore mining or dredging operations can be expected to result in an 25 - 70% reduction of species diversity, 45 - 95% reduction in abundance, and a similar reduction in biomass (Hyllerberg & Nateewathana 1984; Poiner & Kennedy 1984; Kenny & Rees 1994; Morton 1996; Schriever et al. 1997; De Grave & Whitaker 1999; Desprez 2000; Shirayama et al. 2001). Many of these data apply to commercial aggregate extraction or experimental mining of manganese nodules that leave behind trenches of 20 - 30 cm depth only. Benthic macrofauna typically inhabit the top 20 - 30 cm of sediment, so removal of the upper 50 cm is likely to be sufficient to completely eliminate the benthos in the dredged path (Newell et al. 1998). As the remote mining tools currently in use to mine marine diamonds, remove not only the overburden but also the underlying ore body, it can safely be assumed that 100% of the benthic infaunal and epifaunal biota in the path of the mining tool is lost as a direct result of the mining process. As many of the macrofaunal species serve as a food source for demersal and epibenthic fish and crustaceans, cascade effects on higher order consumers may result. For offshore habitats identified by Sink et al. (2011) as ‘least threatened’ (Namaqua sandy inner shelf and Namaqua muddy inner shelf) this reduction in benthic biodiversity can be considered negligible due to the available area of similar habitat

3 The proportions of mineable unconsolidated sediments exclude mudbelt sediment areas.

Pisces Environmental Services (Pty) Ltd 103 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC on the continental shelf of the West Coast. Impacts on higher order consumers are thus unlikely. For the critically endangered Namaqua sandy inshore habitat, restrictions in permissible proportions of the total area disturbed annually is recommended (see Section 5.3.2).

The extraction of the surficial sediments results in the exposure of different seabed sediments than those present prior to the mining or dredging event and/or reduced depth of the original sediment remaining on the seabed. Observed differences in community structure between mined and unmined areas are primarily due to mining-induced changes in physical sediment composition and organic content in mined areas, as these generally tend to have higher proportions of gravel than unmined sites (Parkins & Field 1998; Steffani 2010, 2012; Biccard & Clark 2016). Undisturbed seabed on the continental shelf off the Orange River mouth was often characterised by extensive areas of bio-active sediment, scattered boulders and debris richly encrusted with a diverse epifauna, whereas recently mined areas are typically characterised by a dense cover of clean rock debris, cobbles and gravel, with signs of a reduced infauna. These differences persist in the medium- to long-term, with the recovery rate of the impacted community depending on surface area impacted, the nature of the remaining sediments, and natural infill rate of fine sediments re-mobilisation by seabed currents and swell-turbulence.

Studies on dredging impacts in other parts of the world similarly identified that a markedly different benthic community to that originally present re-colonises the area following the cessation of extraction (Kaplan et al. 1974; Herrmann et al. 1999; Posford Duvivier Environment 2001). For example, Desprez (2000) noted that the original heterogeneous substrate of a shingle bank off the French coast, characterised by gravels and coarse sands, was progressively dominated by fine sands deposited in dredge tracks resulting in the recovering community structure being different from the initial one.

The ecological recovery of the disturbed seafloor is generally defined as the establishment of a successional community of species that achieves a community similar in species composition, population density and biomass to that previously present (Ellis 1996). The rate of recovery (recolonisation) depends largely on the magnitude of the disturbance, the type of community that inhabits the sediments in the mining target area, the extent to which the community is naturally adapted to high levels of sediment disturbances, the sediment character (grain size) that remains following the disturbance, and physical factors such as depth and exposure (waves, currents) (Newell et al. 1998). Provided enough of the original sediment remains in the disturbed area, recolonisation generally starts rapidly after a mining disturbance, and the number of individuals (i.e. species density) may recover within short periods (weeks). Opportunistic species may recover their previous densities within months. Long-lived species like molluscs and echinoderms, however, need longer to re-establish the natural age and size structure of the population. Biomass therefore often remains reduced for several years (Kenny & Rees 1994, 1996; Kenny et al. 1998).

The structure of the recovering communities is typically also highly spatially and temporally variable reflecting the high natural variability in benthic communities at depth. The community developing after an impact depends on (1) the nature of the impacted substrate, (2) differential re-settlement of larvae in different areas, (3) the rate of sediment movement

Pisces Environmental Services (Pty) Ltd 104 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC back into the disturbed areas and (4) environmental factors such as near-bottom dissolved oxygen concentrations etc. At depths beyond the wave base (>40 m) mining excavations will have slow infill rates and may persist for extended periods (years). Long-term or permanent changes in grain size characteristics of sediments may thus occur, potentially resulting in a shift in community structure. Depending on the texture of the sediments at the mining target sites, slumping of adjacent unconsolidated sediments into the excavations can, however, be expected over the very short-term. Although this may result in localised disturbance of macrofauna associated with these sediments and alteration of sediment structure, it also serves as a means of natural recovery of the excavations.

Natural rehabilitation of the seabed following mining operations, through a process involving influx of sediments and recruitment of invertebrates, has been demonstrated on the southern African continental shelf (Penney & Pulfrich 2004; Steffani 2007a, 2007b, 2009, 2010, 2012). Recovery rates of impacted communities were variable and dependent on the mining approach, sediment influx rates and the influence of natural disturbances on succession communities. Results of on-going research on the southern African West Coast suggest that differences in biomass, biodiversity or community composition following mining below the wave base with drill ships or crawlers may endure beyond the medium term (6-15 years) (Parkins & Field 1998; Pulfrich & Penney 1999; Steffani 2012). Savage et al. (2001), however, noted similarities in apparent levels of disturbance between mined and unmined areas off the southern African west coast, and areas of the Oslofjord in the NE Atlantic Ocean, which is known to be subject to periodic low oxygen events. In deep water areas off southern Namibia there is evidence of both significant recruitments and natural disturbances (e.g. low-oxygen events, Orange River floods) in recovering succession communities after mining (Pulfrich & Penney 1999; Biccard et al. 2016; Biccard & Clark 2016). The physical disturbance resulting from sampling or mining may therefore be no more stressful than the regular natural disturbances characterising the continental shelf area of the Benguela ecosystem.

The impacts associated with the removal of seabed sediments and their associated biota would be of medium intensity, but remain relatively localised within each mining block. In critically endangered Namaqua Sandy Inshore and Namaqua Inshore Hard Grounds habitats, impacts would, however be considered of high intensity. In low-energy, deep-water environments where infill rates are slower, natural recovery of communities would occur over the medium- to long-term only and impacts may thus be only partially reversible; establishment of alternative communities is likely to occur over the short- to medium term. The likelihood of impacts to invertebrate macrofauna by offshore mining is definite and adverse effects are considered of MEDIUM to HIGH significance without mitigation and LOW significance with mitigation.

Some disturbance or loss of benthic biota adjacent to the mining footprint can also be expected as a result of the launching of the seabed crawler. Although the mining vessel is dynamically positioned, the setting of anchors may on occasions be required by the mining vessel, or by support vessels. In setting the anchors, benthic epifauna and infauna are likely to be crushed, and in subsequent potential tensioning or dragging of the anchors and anchor chains, macrofauna would be disturbed, thereby resulting in a reduction in benthic biodiversity. The potential area of seabed disturbed would vary with the number of anchors

Pisces Environmental Services (Pty) Ltd 105 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC used, the proportion of anchor chain that lies on the seabed, the forces applied and the duration of mining activities. Perry (2005) reports that for well-drilling operations conducted in 350-450 m depth, the area disturbed per (10 tonne) anchor was estimated at 5 m wide by 200 m long, with an additional disturbance area of 2 m wide by up to 300 m long from each section of anchor chain. Similarly, epifauna and infauna beneath the footprint of the crawler tracks in the ‘launch pad’ area adjacent to the mining block would be crushed by the weight of the equipment resulting in a reduction in benthic biodiversity.

Crushing of organisms in the impact depressions and scars is likely to primarily affect soft- bodied species as some molluscs and crustaceans may be robust enough to survive (see for example Savage et al. 2001). Considering the available area of similar habitat on the continental shelf of the West Coast (even in critically endangered habitats), the reduction in benthic biodiversity through crushing by crawler and anchors can be considered negligible. The impacts would be of low intensity but highly localised, and short-term as recolonization would occur rapidly from adjacent undisturbed sediments. The potential impact is consequently deemed to be of VERY LOW significance.

Disturbance and loss of biota in offshore unconsolidated sediments

Without Mitigation Assuming Mitigation Extent Local: restricted to mining targets Local Duration Medium- to Long-term Medium -term Intensity Medium to High (critically Medium endangered habitats) Probability Definite Probable Confidence High High Status Negative Negative Significance Medium to High (critically Low endangered habitats)

Reversibility Partially (critically endangered habitats) to Fully reversible Mitigation Potential Low to Medium

Crushing of benthic fauna by crawler and anchors

Without Mitigation Assuming Mitigation Extent Local Local Duration Short-term Short-term Intensity Low Low Probability Definite Definite Confidence High High Status Negative Negative Significance Very Low Very Low

Reversibility Fully reversible Mitigation Potential None

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Mitigation No mitigation measures are possible for the direct loss of macrobenthos as a result of mining operations or the indirect loss of benthic macrofauna due to crushing by the seabed crawler tracks or anchors and chains. However, the following best practice management measures are proposed:

General

 An Environmental Code of Practice (ECOP) must be prepared for each contractor. The ECOP will be specific to each operational area and will include specifications for:

 Environmental considerations (i.e. identification of sensitive receptors) and establishment of ‘no-go’ areas  The mining target area  Waste management (including tailings discard requirements such as discharging tailings back into mined-out areas, avoiding tailings disposal on reefs, investigating use of subsurface tailings disposal chutes)  Rehabilitation specifications (including monitoring requirements by the Mining Licence holder)  Establishment of a monitoring fund to which all contractors contribute  Undertake Environmental Awareness Training to ensure the vessel’s personnel are appropriately informed of the purpose and requirements of the EMPr. Vessel-based diver operations  Mining of any nature should not be permitted in nearshore habitats (with restricted representation) identified as critically endangered by the SANBI’s National Biodiversity Assessment (Sink et al. 2011) (Namaqua inshore reefs, Namaqua Mixed Shores). If, however, prospecting / mining is proposed within these areas an independent assessment of the habitats and associated biota should be undertaken by a suitably qualified ecologist to verify the habitat status. Should it be confirmed that the habitats are indeed ecologically unique, these areas should be declared ‘no-go’ areas and any future prospecting / mining there should be prohibited.

 In the case of Namaqua Inshore Hard Grounds, Namaqua Mixed Shores and Namaqua Sandy Inshore habitats, which are represented by more extensive areas, the area disturbed annually by mining should be limited to less than 1% of the available habitat within the mining licence area, unless the habitat is confirmed to be different by a suitably qualified ecologist.

 Do not collect any shellfish (including abalone, rock lobster, mussels) or undertake recreational or subsistence fishing within the mining area or the McDougall’s Bay rock lobster sanctuary.

Remote mining operations

 Mining should avoid unconsolidated habitats in the close proximity of rocky outcrop areas. This should include a suitable buffer zone (> 500 m) around identified sensitive areas to ensure that these are not affected indirectly by tailings impacts.

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 The area disturbed annually by mining in the Namaqua Inshore Hard Grounds and Namaqua Sandy Inshore habitats, which are represented by more extensive areas, should be limited to less than 1% of the available habitat within the mining licence area annually, unless the habitats are confirmed to be different by a suitably qualified ecologist.

 Integrated environmental management measures implemented as part of the mining activities should include a well-structured monitoring programme the principal objective of which is to demonstrate natural recovery processes by means of pre- and post-mining seabed and benthic faunal community surveys. Pre-mining baseline data should be collected for at least two (preferably three) consecutive years pre-mining in areas where mining activities are planned and changes in the benthic community structures in impacted areas should be regularly assessed. Details are provided in the monitoring plan (see Section 7).

5.3.2 Discharge of tailings from classifiers and on-board treatment plants and redistribution of cofferdam wall sediments The project activities that will generate tailings are described further below:

 Shore-based, diver-assisted operations in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A) pump the mined gravel ashore to classifiers located in the intertidal zone. Oversize tailings (>20 mm) accumulate around the screening units and fines (<1.6 mm) are returned to the sea across the intertidal regions as a sediment slurry.

 Sampling and test mining operations in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A) by ‘walk-in’ jack-up platforms would involve onboard screening with the oversize material (>25 mm) and fines (<1.4 mm) being disposed of back into the sea.

 Cofferdam operations in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A) requires the constant maintenance of the seawall with non- native sediments. Finer materials are constantly eroded and redistributed by wave action.

 Vessel-based diver-mining contractors operating in Licence 554MRC (Sea Concession 1A, 2A and 3A) and Licence 512MRC (Sea Concession 4A), pump gravels to onboard classifiers. Fine material from the classifier washes directly back into the sea whilst the oversize fraction (>20 mm) is discharged directly overboard. Some vessels are fitted with ‘blower’ cowlings, which direct the thrust of the propeller downwards to displace the overlying fine sediments.

 Test-mining (bulk sampling) and mining in Licence 554MRC (Sea Concession 1B), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C), would involve the excavation of unconsolidated seabed sediments using either large-diameter drills, dredge pump, airlift systems or seabed crawlers. All excavated sediments are brought to

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the surface using airlifts or pumps, where they are screened, classified and sorted, with fines, oversize and screened waste-gravel being returned directly to the sea. Impact description and assessment Smothering of benthic biota by re-depositing tailings During the mining process, overburden sediments and target gravels are pumped to the classifiers located on the shore or to the mining vessel at the sea surface and discharged onto sorting screens, which separate the large gravel, cobbles and boulders and fine silts from the ‘plantfeed’. In shore-based operations, coarse tailings accumulate around the classifiers smothering and crushing underlying biota. If the classifiers are located in the intertidal zone, tailings will be redistributed by wave action over the short- to medium term, and during this redistribution process scouring of existing communities is likely to occur. If coarse tailings are deposited above the high water mark, redistribution would not occur and the sterile tailings heaps would persist over the long term / permanent.

On mining vessels, the oversize tailings are discarded overboard and settle back onto the seabed beneath the vessel. In the deep-water operations (in Sea Concessions 1B, 4B and 1C) tailings discharged from the mining vessel amounts to 99.9% of the sediments mined. Following discharge overboard of the fine and coarse tailings, these settle back onto the seabed where they can result in smothering of benthic communities adjacent to the mined areas. Smothering involves physical crushing, a reduction in nutrients and oxygen, clogging of feeding apparatus, as well as affecting choice of settlement site, and post-settlement survival. The significance of such discharges will depend not only on the nature and volume of tailings being discarded, but also the nature of the receiving environment.

Studies investigating the dumping of the oversize tailings during diver-assisted mining found that impacts of these discards on shallow-water and nearshore benthic reef communities persisted over the short-term only (Pulfrich & Penney 2001). If overburden gravels and coarse tailings mined by diver-assisted, vessel-based operations were discarded directly back into mined out gullies, smothering effects were negligible. If discards occurred on reefs the nature of the seabed is physically altered, and the benthic communities in the affected areas were found to be significantly different from those on adjacent reefs not affected by tailings. These effects were not only extremely localised but ephemeral, as tailings were rapidly redistributed by swell action and any resultant impacts were negligible when seen in context with the high levels of natural disturbance in the nearshore environment. In more sheltered gullies, however, accumulated overburden and tailings act as traps for particulate detritus, resulting in the attraction of detritus feeders such as brittle stars and sea cucumbers.

In deeper water beyond the wave base, the deposition of the coarser tailings fraction would have more of an impact on the soft-bottom benthic community than gradual sedimentation of fine sediments to which benthic organisms are adapted and able to respond. Typically, the coarse tailings accumulate within a few 100 m of the mining vessel, although depending on the strength of prevailing current, some may disperse further as a sediment plume. If these coarse tailings deposit on unmined seabed communities beyond the block currently being mined, they could effectively change the the benthic habitat from one dominated by unconsolidated sediments to one dominated by gravel and boulders, with concomitant changes in benthic community structure. The fine fraction would be dispersed over a wider area by prevailing

Pisces Environmental Services (Pty) Ltd 109 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC currents and settle gradually as a thinner mantle over the seabed. This deposition would have less of an impact on the soft-bottom benthic community as macrofauna off the Orange River mouth would be adapted to respond to natural gradual sedimentation. Studies have shown that some mobile benthic animals are capable of actively migrating vertically through overlying sediment thereby significantly affecting the recolonization of impacted areas and the subsequent recovery of disturbed areas of seabed (Maurer et al. 1979, 1981a, 1981b, 1982, 1986; Ellis 2000; Schratzberger et al. 2000; but see Harvey et al. 1998; Blanchard & Feder 2003). In contrast, sedentary communities may be adversely affected by both rapid and gradual deposition of sediment. Filter-feeders are generally more sensitive to suspended solids than deposit-feeders, since heavy sedimentation may clog the gills. Impacts on highly mobile invertebrates and fish are likely to be negligible since they can move away from areas subject to redeposition.

Of greater concern is that tailings discarded during deep-water mining operations may impact rocky outcrop communities adjacent to mining targets potentially hosting sensitive deep-water coral communities. Although the seabed in Sea Concession 1C is dominated by unconsolidated sediments, 29.7% of Concession 1B comprises bedrock. As video footage from South Africa and to the south-east of Childs Bank has identified vulnerable communities including gorgonians, bryozoans and octocorals, the potential occurrence of such sensitive deep-water ecosystems in the Concession 1B and 1C cannot be excluded. However, considering the proximity of the Orange River to Sea Concession 1B, any biota occurring on hard substrata would be expected to be adapted to elevated suspended sediment concentrations. As deep-water corals tend to occur in areas with low sedimentation rates (Mortensen et al. 2001), these benthic suspension- feeders and their associated faunal communities are likely to show particular sensitivity to increased turbidity and sediment deposition associated with tailings discharges. Exposure of elevated suspended sediment concentrations can result in mortality of the colony due to smothering, alteration of feeding behaviour and consequently growth rate, disruption of polyp expansion and retraction, physiological and morphological changes, and disruption of calcification. While tolerances to increased suspended sediment concentrations will be species specific, concentrations as low as 100 mg/l have been shown to have noticeable effects on coral function (Roger 1999).

Supratidal (High Shore)

The discharge of tailings around classifiers located in the high shore would be of medium intensity, but would be permanent if not actively removed. If tailings discards occur in critically endangered (Namaqua Sheltered Rocky Coast) or endangered (Namaqua Mixed Shore) habitats, the intensity would be high. Although impacts would be limited to a scale of a few 10s of metres around each individual operation, shore-based diver operations have been established throughout the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A in Licence 554MRC, and the extent can thus be considered regional. Impacts are definite and would be irreversible if not actively mitigated. The significance of the impact of discarding tailings in the high shore is thus considered HIGH to VERY HIGH without mitigation, reducing to LOW significance with the implementation of mitigation measures.

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Intertidal and Shallow Subtidal

Impacts associated with the discard of tailings from classifiers located in the intertidal and diver-assisted vessels would be of medium intensity, persisting over the short term only as they would be rapidly redistributed by wave action. If tailings discards occur in critically endangered (Namaqua Inshore Reef, Namaqua Inshore Hard ground and Namaqua Sheltered Rock Coast) or endangered (Namaqua Mixed Shore) habitats, the intensity would be high. Although impacts would be limited to a scale of a few 10s of metres around each individual operation, diver-assisted operations have been established throughout the surf zones and shallow portions of Sea Concessions 1A, 2A, 3A and 4A (vessels only), and the extent can thus be considered regional. Impacts are probable, and would be fully reversible. The impact of tailings discarged in the intertidal zone and in nearshore waters is considered to be of LOW to MEDIUM significance without mitigation, reducing to VERY LOW significance with mitigation.

Deeper water (>5 m)

The smothering impacts on benthic macrofauna in unconsolidated sediments in deeper water (>5 m) due to the discard of tailings from mining vessels would be of medium intensity (regardless of the threat status of the benthic habitat), but remain relatively localised within each mining target area. Impacts would persist over the short term for diver-assisted operations in the A-concessions as tailings would be rapidly redistributed by wave action), but medium-term where mining occurs in deeper water beyond the wave base (B- and C- concessions). In shallower water impacts would be fully reversible, whereas in deeper water impacts may be only partially reversible. Establishment of alternative communities in the altered habitat would, however, occur over the short-term. The likelihood of impacts to invertebrate macrofauna of unconsolidated sediments by tailings discharges is probable and adverse effects are considered of VERY LOW to LOW significance without mitigation, and of VERY LOW significance with mitigation.

Impacts associated with the discard of tailings from offshore remote mining operations on deep-water reefs adjacent to mining targets would be of medium intensity, but remaining relatively localised within and around each mining target area. In low-energy deep-water environments, impacts could persist over the medium term and potentially be only partially reversible. The likelihood of impacts to invertebrate macrofauna of deep-water rocky outcrop communities by tailings discharges is possible and adverse effects are considered of VERY LOW significance without mitigation, reducing to INSIGNIFICANT with mitigation.

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Smothering of highshore communities and alteration of habitat by discarded tailings

Without Mitigation Assuming Mitigation Extent Regional: full extent of surf zone Regional concessions Duration Permanent Short-term Intensity Medium to High (critically Medium endangered habitats) Probability Definite Probable Confidence High High Status Negative Neutral Significance High to Very High (critically Low endangered habitats)

Reversibility Irreversible Mitigation Potential High

Smothering of intertidal and nearshore reef communities and alteration of habitat by discharged tailings Without Mitigation Assuming Mitigation Extent Regional: full extent of surf zone Regional and A-concessions concessions Duration Short-term Short-term Intensity Medium to High (critically Low endangered habitats) Probability Probable Probable Confidence High High Status Negative Negative Significance Low to Medium (critically Very Low endangered habitats)

Reversibility Fully reversible Mitigation Potential Medium

Smothering of macrofauna in offshore (>5 m) unconsolidated sediments and alteration of habitats by discharged tailings Without Mitigation Assuming Mitigation Extent Local: full extent of A-, B- and C- Regional concessions concessions Duration Short- to Medium-term Short-term Intensity Medium Low Probability Probable Probable Confidence High High Status Negative Negative Significance Very Low (inshore) to Low (offshore) Very Low

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Reversibility Fully reversible Mitigation Potential Low

Smothering of deep-water rocky outcrop communities by discharged tailings

Without Mitigation Assuming Mitigation Extent Local: limited to mining targets Local Duration Medium-term Short-term Intensity Medium Low Probability Possible Improbable Confidence High High Status Negative Negative Significance Very Low Insignificant

Reversibility Partially reversible Mitigation Potential Low

Mitigation No mitigation measures are possible for the indirect impacts of smothering and alteration of habitats through discharge of tailings from mining vessels. However, the following best practice management measures are proposed:

General

 An Environmental Code of Practice (ECOP) must be prepared for each contractor (refer to Section 5.2.1.1 and 5.2.1.3 for the contents of onshore and offshore ECOPs, respectively).

 Mining should not be permitted in nearshore habitats (with restricted representation) identified as critically endangered (Namaqua inshore reefs and Namaqua Sheltered Rocky Coast) (all mining methods) or endangered (Namaqua Mixed Shore habitat) (coffer dam mining only) by the SANBI’s National Biodiversity Assessment (Sink et al. 2011). If, however, prospecting / mining is proposed within these areas an independent assessment of the habitats and associated biota should be undertaken by a suitably qualified ecologist to verify the habitat status. Should it be confirmed that the habitats are in deed ecologically unique, these areas should be declared ‘no-go’ areas and any future prospecting / mining there should be prohibited.

 Restrict mining within the endangered Namaqua Mixed Shore (for driver assisted mining and mobile pump unit operations) and critically endangered Namaqua Inshore Hard Grounds and Namaqua Sandy Inshore habitats (for vessel-based diver assisted and remote mining), which are represented by more extensive areas off the West Coast, to less than 1% of the available habitat within the mining licence area annually, unless the habitats are confirmed to be different by a suitably qualified ecologist.

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 For diver-assisted operations vessels should be positioned in such a way that tailings are discharged back into mined out gullies or into areas of unconsolidated sediment adjacent to mining targets.

 Use should be made of existing geophysical data to conduct a pre-mining geohazard analysis of the seabed to map potentially vulnerable habitats and prevent potential conflict with the mining targets. The SANBI benthic habitat maps should be incorporated into the company’s GIS mapping so as to identify potential overlap of current and future mining targets with endangered and critically endangered habitats. This information should be included in the ECOP for contractors.

 For deep-water operations in Sea Concessions 1B, 1C, and 4B mining activities should avoid targeting areas of unconsolidated sediments in close proximity to rocky outcrop areas identified by the pre-mining geohazard seabed analysis. This should include a suitable buffer zone (> 500 m) around identified sensitive areas to ensure that these are not affected indirectly by plume impacts.

Monitoring

 Integrated environmental management measures implemented as part of the mining activities should include a well-structured monitoring programme the principal objective of which is to demonstrate natural recovery processes by means of pre- and post-mining seabed and benthic faunal community surveys. Pre-mining baseline data should be collected in areas where mining activities are planned and changes in the benthic community structures in impacted areas should be regularly assessed. Details are provided in the monitoring plan (see Section 7).

Increased water turbidity and reduced light penetration Impact description and assessment Suspended sediment plumes are generated by all mining operations, regardless of the mining approach. These occur near the seabed through re-suspension of fine sediments by the mining tool, by the discharge of fine sediments from classifiers and onboard processing plants into the sea, and by the constant erosion of finer materials from cofferdam walls by wave action.

The finer components of surface discharges generate a plume in the upper water column, which is dispersed away from the point of discharge by prevailing currents, diluting rapidly to background levels at increasing distances from the mining vessel. Distribution and re- deposition of suspended sediments are the result of a complex interaction between oceanographic processes, sediment characteristics and engineering variables that ultimately dictate the distribution and dissipation of the plumes in the water column. Ocean currents, both as part of the meso-scale circulation and due to local wind forcing, are important in distribution of suspended sediments. Turbulence generated by surface waves can also increase plume dispersion by maintaining the suspended sediments in the upper water column.

One of the more apparent effects of increased concentrations of suspended sediments and consequent increase in turbidity, is a reduction in light penetration through the water column

Pisces Environmental Services (Pty) Ltd 114 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC with potential adverse effects on the photosynthetic capability of phytoplankton and macrophytes. Poor visibility may also inhibit pelagic visual predators. However, due to the rapid dilution and widespread dispersion of settling particles, any adverse effects in the water column would be ephemeral and highly localised. Turbid water is a natural occurrence along the southern African west coast, resulting from aeolian and riverine inputs, resuspension of seabed sediments in the wave-influenced nearshore areas and seasonal phytoplankton production in the upwelling zones. The development of invertebrate and fish eggs and/or larvae may be impaired through high sediment loading, but as the major spawning areas are all located on the continental shelf, south of the concession areas , any potential effects of turbid water plumes generated during tailings disposal on phytoplankton and ichthyoplankton production, fish migration routes and spawning areas, or on benthic and demersal species in the area would thus be negligible. Increased turbidity of near-bottom waters through resuspension of fine sediments by mining tools, may place transient stress on sessile and mobile benthic organisms, by negatively affecting filter-feeding efficiency of suspension feeders or through disorientation due to reduced visibility (reviewed by Clarke and Wilber 2000). However, in most cases sub-lethal or lethal responses occur only at concentrations well in excess of those anticipated at the seabed and in the water column. Benthic species that may be impacted by near-bottom plumes include bivalves and crustaceans. Suspended sediment effects on juvenile and adult bivalves occur mainly at the sublethal level with the predominant response being reduced filter-feeding efficiencies at concentrations above about 100 mg/. Lethal effects are seen at much higher concentrations (>7,000 mg/) and at exposures of several weeks. Furthermore, as marine communities in the Benguela are frequently exposed to naturally elevated suspended-sediment levels, they can be expected to have behavioural and physiological mechanisms for coping with this feature of their habitat.

The impact of increased turbidity in the water column due to overboard discharge of tailings and elevated suspended sediment concentrations at the seabed around the mining tool would thus be of low intensity, persisting only over the very short term (days), and would be localised (<20 km radius of the mine site). Any possible adverse effects on sessile benthos, or on the feeding, spawning and recruitment of mobile predators, will be fully reversible. The biochemical impact of reduced water quality through increased turbidity can thus confidently be rated as being INSIGNIFICANT without mitigation.

In the case of sediments eroded from cofferdams, however, the impacts of increased turbidity and mobilised sediments in the surf zone would be of medium intensity, persisting for as long as the cofferdam walls are maintained (short term by definition). As turbidity plumes can become trapped in the surf zone, impacts could probably extend regionally. Impacts should, however, be fully reversible once cofferdam operations cease. The biochemical impact of reduced water quality due to eroded sediments from cofferdam operations would thus be rated as being of MEDIUM significance without mitigation.

Mitigation No mitigation measures are possible for the discharge of tailings from the mining vessel, the resuspension of seabed sediments by mining tools or the erosion of cofferdam materials by wave action.

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Impacts of tailings discharge on water column and bottom-water biochemistry (turbidity and light) Without Mitigation Assuming Mitigation Extent Local: limited to mining area Duration Short-term Intensity Low Probability Possible No mitigation is proposed Confidence High Status Negative Significance Insignificant

Reversibility Fully reversible Mitigation Potential None

Impacts of sediments eroded from cofferdam walls on water column and bottom-water biochemistry (turbidity and light) Without Mitigation Assuming Mitigation Extent Regional Duration Short-term Intensity Medium Probability Probable No mitigation is proposed Confidence High Status Negative Significance Medium

Reversibility Fully reversible Mitigation Potential None

Reduced physiological functioning of marine organisms due to indirect biochemical effects Impact description and assessment A further indirect impact (i.e. impacts arising indirectly from biochemical effects on the sediments) associated with tailings disposal in the deeper waters of Sea Concession 1B, 1C and 4B is the potential development of hypoxic conditions in the near-surface sediment layers through bacterial decomposition of organic matter. Biodegradable organic matter in tailings piles on the seabed often has a greater effect than sediment texture and deposition rate on the structure and function of benthic communities (Hartley et al. 2003). Bacterial decomposition of organic matter may deplete oxygen in the near-surface sediment layers, thereby changing the chemical properties of the sediments by generating potentially toxic concentrations of sulfide and ammonia (Wang and Chapman 1999; Gray et al. 2002; Wu 2002). Organically enriched sediments are often hypoxic or anoxic, and consequently harbour markedly different benthic communities to oxygenated sediments (Pearson and Rosenberg 1978; Gray et al. 2002). Where inputs of organic matter are pulsed, their concentrations in the sediments would decrease with time in response to microbial degradation, and oxygen concentration in the surface-sediment layers would again recover leading to succession in the benthic community

Pisces Environmental Services (Pty) Ltd 116 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC structure toward a more stable state. In shallower waters (Sea Concessions 1A, 2A, 3A and 4A) where sediments are constantly resuspended by wave action, the development of hypoxic sediments following tailings disposal is highly unlikely.

Marine organisms respond to hypoxia by first attempting to maintain oxygen delivery (e.g. increases in respiration rate, number of red blood cells, or oxygen binding capacity of haemoglobin), then by conserving energy (e.g. metabolic depression, down regulation of protein synthesis and down regulation/modification of certain regulatory enzymes), and upon exposure to prolonged hypoxia, organisms eventually resort to anaerobic respiration (Wu 2002). Hypoxia reduces growth and feeding, which may eventually affect individual fitness. The effects of hypoxia on reproduction and development of marine animals remains almost unknown. Many fish and marine organisms can detect, and actively avoid hypoxia. Some macrobenthos may leave their burrows and move to the sediment surface during hypoxic conditions, rendering them more vulnerable to predation. Hypoxia may eliminate sensitive species, thereby causing changes in species composition of benthic, fish and phytoplankton communities. Decreases in species diversity and species richness are well documented, and changes in trophodynamics and functional groups have also been reported. Under hypoxic conditions, there is a general tendency for suspension feeders to be replaced by deposit feeders, demersal fish by pelagic fish and macrobenthos by meiobenthos (see Wu 2002 for references). Further anaerobic degradation of organic matter by sulphate-reducing bacteria may additionally result in the production of hydrogen sulphide, which is detrimental to marine organisms (Brüchert et al. 2003).

The bulk of the seawater in the area comprises South Atlantic Central Water (SACW), which has depressed oxygen concentrations (~80 % saturation value), with lower oxygen concentrations (<40% saturation) occurring frequently due to nutrient remineralisation in bottom waters. The Orange River Bight is also recognised as one of the two main areas of low-oxygen water formation in the southern Benguela region. The benthic communities in the PSJV Sea Concessions will therefore be adapted to low oxygen conditions and will be characterised either by species able to survive chronic hypoxia, or colonising and fast-growing species able to rapidly recruit into areas that have suffered oxygen depletion.

Development of anoxic conditions beneath re-deposited tailing in the deeper waters of Sea Concession 1B, 1C and 4B is highly unlikely due to the low deposition thicknesses anticipated in the tailings fallout footprint. Should anoxic conditions develop, these would have an impact of low intensity on the benthic macrofauna, with recovery expected within a few months. The likelihood of the impact occurring is considered ‘improbable’ with any potential effects being fully reversible. The impact is thus considered to be INSIGNIFICANT without mitigation.

Mitigation No additional mitigation measures for potential indirect biochemical effects in seabed sediments are proposed or deemed necessary.

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Indirect Impacts of Tailings Discharges: development of anoxic sediments Without Mitigation Assuming Mitigation Extent Local: limited to mining site. Duration Short-term: erosion and dispersal of tailings should occur within a few months Intensity Low: West Coast biota are naturally adapted to low oxygen conditions No mitigation is proposed Probability Improbable Status Negative Confidence Medium Significance Insignificant

Reversibility Fully reversible Mitigation Potential None

Toxicity and bioaccumulation effects on marine fauna Impact description and assessment A number of historical studies suggested that recently deposited sediments in specific areas on the continental shelf of the southern African West Coast may be characterised by high levels of heavy metals of marine and/or terrestrial origin (Calvert & Price 1970; Chapman & Shannon 1985; Bremner & Willis 1990). Unpublished data by Bremner & Willis (cited in Environmental Evaluation Unit 1996) found high levels of cobalt (Co), manganese (Mn) and nickel (Ni) associated with suspended sediments during the 1988 Orange River floods, suggesting the Orange River catchment area is a significant source of these contaminants. Measurements of metal concentrations from vibrocore samples taken in the Namibian Atlantic 1 Mining Licence Area confirm high levels of metals in sediments (Environmental Evaluation Unit 1996). The re- suspension of sediments during mining can release these trace metals into the water column.

Although contaminant levels in plumes from deep-water mining vessels operational both to the south (Steffani & Pulfrich 2004; Carter 2008), as well as to the north of the Orange River mouth (CSIR 2006) found that heavy metal concentrations did not exceeded the SA chronic water- quality guidelines or the “prohibition limit” as imposed by the London Convention, for any of the measured contaminants, trace metal analysis of sediments collected in Sea Concessions 1B and 1C indicated that levels of Cobalt, Iron, Vanadium, Nickel, Copper, Cadmium and Arsenic were in excess of recommended guideline levels required to sustain natural ecosystem functioning (Mostert et al. 2016). The bioavailability of these metals was, however, not determined.

Metal bio-availability and eco-toxicology is complex and depends on the partitioning of metals between dissolved and particulate phases and the speciation of the dissolved phase into bound or free forms (Paulson & Amy 1993; Rainbow 1995; Galvin 1996). Although dissolved forms are regarded as the most bio-available, many of these are not readily utilisable by aquatic organisms. Consequently those forms that are ultimately bio-available and potentially toxic to marine organisms usually constitute only a fraction of the total concentration. Trace metal

Pisces Environmental Services (Pty) Ltd 118 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC uptake by organisms may occur through direct absorption from solution, by uptake of suspended matter and/or via their food source. Toxic effects on organisms may be exerted over the short term (acute toxicity), or longer term through bioaccumulation. Plumes generated during mining and dredging are highly dynamic and any contaminants therein would be rapidly diluted, and impacts would thus be of low intensity. Furthermore, as potentially susceptible organisms are highly mobile pelagic species, neither acute effects nor bioaccumulation are likely to be of concern. The impacts associated with the release of contaminants from disturbed sediments in Sea Concessions 1B, 1C and 4B would remain localised, persisting only over the short-term. The likelihood of impacts occurring is considered improbable, and as these would be fully reversible any potential adverse effects is therefore considered to be INSIGNIFICANT without mitigation.

Mitigation No additional mitigation measures for potential indirect toxicity and bioaccumulation effects on marine organisms are proposed or deemed necessary.

Biochemical Impacts of heavy metals in tailings on marine organisms Without Mitigation Assuming Mitigation Extent Local Duration Short-term Intensity Low Probability Improbable No mitigation is proposed Status Negative Confidence Medium Significance Insignificant

Reversibility Fully reversible Mitigation Potential None

5.3.3 Disturbance of marine biota by noise The project activities that will generate noise in the marine environment are described further below:

 During geophysical surveys, in Licence 554MRC (Sea Concession 1A, 2A, 3A and 1B), Licence 512MRC (Sea Concession 4A), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C), multibeam echosounders and sub-bottom profilers would be used. Multibeam echosounders transmit a 30 kHz sounding in a wide swath below the vessel to produce high resolution digital terrain models of the seafloor. In contrast, sub- bottom profilers use shallow (35 to 45 kHz) and medium penetration (1 to 10 kHz) “Chirp” seismic pulses to generate profiles up to 60 m beneath the seafloor, thereby giving a cross section view of the sediment layers. Sound levels from the acoustic equipment would range from 190 to 220 dB re 1 μPa at 1 m.

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 Sampling and mining activities in Licence 554MRC (the surf zones opposite Farm 1 and Farm 155 and Sea Concession 1A, 2A, 3A and 1B), Licence 512MRC (Sea Concession 4A), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C), the mining vessels, as well as the sampling and mining tools (suction nozzles, vibrocorers, megadrill, fixed-head trenching tools, Wirth drill or seabed crawler) would generate a range of underwater noises into the surrounding water column that may potentially contribute to and/or exceed ambient noise levels in the area.

 Crew transfers by helicopter from Alexander Bay or Kleinzee, depending on the location of sampling or mining, to the offshore mining vessels will generate noise in the atmosphere that may disturb coastal species such as seabirds and seals.

Impact description and assessment 5.3.3.1 Generation of underwater noise

The ocean is a naturally noisy place and marine animals are continually subjected to both physically produced sounds from sources such as wind, rainfall, breaking waves and natural seismic noise, or biologically produced sounds generated by other species. Such acoustic cues are thought to be important to many marine animals in the perception of their environment as well as for navigation purposes, predator avoidance, and in mediating social and reproductive behaviour. Anthropogenic sound sources in the ocean may thus interfere directly or indirectly with such activities. Of all human-generated sound sources, the most persistent in the ocean is the noise of shipping. Depending on size and speed, the sound levels radiating from vessels range from 160 to 220 dB re 1 µPa at 1 m (NRC 2003). Especially at low frequencies between 5 to 100 Hz, vessel traffic is a major contributor to noise in the world’s oceans, and under the right conditions, these sounds can propagate 100s of kilometres thereby affecting very large geographic areas (Coley 1994, 1995; NRC 2003; Pidcock et al. 2003). Other forms of anthropogenic noise include 1) multi-beam sonar systems 2) seismic acquisition, 3) hydrocarbon and mineral exploration and recovery, 4) aircraft flyovers, and 5) noise associated with underwater blasting, pile driving, and construction (Figure 5-3).

Noise propagation represents energy travelling either as a wave or a pressure pulse through a gas or a liquid. Due to the physical differences between air and water (density and the speed at which sound travels), the decibel units used to describe noise underwater are different from those describing noise in air. Furthermore, hearing sensitivities vary between species and taxonomic groups. Underwater noise generated by drilling activities is therefore treated separately from noise generated in the air.

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Figure 5-3: Comparison of noise sources in the ocean (Goold & Coates 2001).

The cumulative impact of increased background anthropogenic noise levels in the marine environment is an ongoing and widespread issue of concern (Koper & Plön 2012). Reactions of marine fauna to anthropogenic sounds have been reviewed by McCauley (1994), Richardson et al. (1995), Gordon & Moscrop (1996) and Perry (1998), who concluded that elevated underwater noise can directly or indirectly affect marine fauna, including cetaceans, by:  causing direct physical injury to hearing or other organs;  masking or interfering with other biologically important sounds (e.g. communication, echolocation, signals and sounds produced by predators or prey);  causing disturbance to the receptor resulting in behavioural changes or displacement from important feeding or breeding areas.

There is considerable difference in the hearing sensitivities of marine animals (McCauley 1994) (Table 5-1). It is the received level of the sound, however, that has the potential to traumatise or cause physiologicl injury to marine animals. As sound attenuates with distance, the received level depends on the animal’s proximity to the sound source and the attenuation characteristics of the sound.

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Table 5-1: Known hearing frequency and sound production ranges of various marine taxa (Koper & Plön 2012).

Hearing frequency Sound production Taxa Order (kHz) (kHz) Shellfish Crustaceans 0.1 – 3 Snapping shrimp Alpheus/ Synalpheus spp. 0.1 - >200 Ghost crabs Ocypode spp. 0.15 – 0.8 Fish Teleosts 0.4 – 4 Hearing specialists 0.03 - >3 Hearing generalists 0.03 – 1 Sea turtles Chelonia 0.1 – 1 Unknown Sharks and skates Elasmobranchs 0.1 – 1.5 Unknown Seals Pinnipeds 0.25 – 10 1 – 4 Northern elephant Mirounga agurostris 0.075 – 10 seal Manatees and dugongs Sirenians 0.4 – 46 4 – 25 Toothed whales Odontocetes 0.1 – 180 0.05 – 200 Baleen whales Mysticetes 0.005 – 30 0.01 – 28

5.3.3.2 Physiological injury in response to geophysical surveying

The noise generated by the acoustic equipment utilized during geophysical surveys falls within the hearing range of most fish and marine mammals, and at sound levels of between 190 to 220 dB re 1 μPa at 1 m, would be audible for considerable distances (in the order of tens of km) before attenuating to below threshold levels (Findlay 2005). However, unlike the noise generated by airguns during seismic surveys, the emission of underwater noise from geophysical surveying and vessel activity is not considered to be of sufficient amplitude to cause auditory or non-auditory trauma in marine animals in the region. Only directly below the systems (within metres of the sources) would sound levels be in the 220 dB range where exposure could result in trauma. As most pelagic species likely to be encountered during surveying are highly mobile, they would be expected to flee and move away from the sound source before trauma could occur.

The impact on marine fauna of noise generated during geophysical surveying operations, is considered to be of medium intensity, and restricted to the survey area over the short-term only. It is probable that the noise generated during surveying may cause physiological injury, and should any impacts occur, these would be fully reversible. The impact is thus considered of VERY LOW significance without mitigation and INSIGNFICANT with mitigation.

Mitigation Despite the very low significance of impacts, the Joint Nature Conservation Committee (JNCC) provides a list of guidelines to be followed by anyone planning marine sonar operations that could cause acoustic or physical disturbance to marine mammals (JNCC 2010). These have been revised to be more applicable to the southern African situation.

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 Onboard Marine Mammal Observers (MMOs) should conduct visual scans for the presence of cetaceans around the survey vessel prior to the initiation of any acoustic impulses.  Pre-survey scans should be limited to 15 minutes prior to the start of survey equipment.  Surveying should only commence once it has been confirmed for a 15-minute period (visually during the day) that there is no cetacean activity within 500 m of the vessel.  “Soft starts” should be carried out, after the pre-survey scan, for any equipment of source levels greater than 210 dB re 1 μPa at 1 m over a period of 20 minutes to give adequate time for marine mammals to leave the vicinity. However, if after a period of 15 minutes small cetaceans (particularly dolphins) are still within 500 m of the vessel, the normal “soft-start” procedure should be allowed to commence.  Terminate the survey if any marine mammals show affected behaviour within 500 m of the survey vessel or equipment until the mammal has vacated the area.  Avoid planning geophysical surveys during the movement of migratory cetaceans (particularly baleen whales) from their southern feeding grounds into low latitude waters (beginning of June to end of November), and ensure that migration paths are not blocked by sonar operations. As no seasonal patterns of abundance are known for odontocetes occupying the proposed exploration area, a precautionary approach to avoiding impacts throughout the year is recommended.  Ensure that PAM (passive acoustic monitoring) is incorporated into any surveying with source levels > 210 dB re 1 μPa at 1 m taking place between June and November.  A MMO should be appointed to ensure compliance with mitigation measures during seismic geophysical surveying.

Physiological injury in Marine Fauna due to noise from geophysical surveys Without Mitigation Assuming Mitigation Extent Local: limited to mining site Local Duration Short-term: for duration of operations Short-term Intensity Medium Low Probability Probable Possible Status Negative Negative Confidence High High Significance Very Low Insignificant

Reversibility Fully reversible Mitigation Potential Low

5.3.3.3 Behavioural changes and masking of biologically-relevant sounds in marine fauna in response to geophysical surveying and underwater mining noise

The sound level generated by seabed crawler operations fall within the 120-190 dB re 1 µPa range at the mining vessel, with main frequencies less than 0.2 kHz (Findlay 2005). Noise levels from hydrocarbon drilling units range from 170 – 190 dB re 1 µPa (Croft and Li 2017) attenuating to below median ambient background level (100 dB re 1µPa) within a distance of 14 - 32 km from the mining site, depending on the specific vessels used and the number of

Pisces Environmental Services (Pty) Ltd 123 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC support vessels operating. Noise levels from shallow-water operations have not been measured but are expected to fall below those for cutterhead dredgers working in comparatively shallow environments where peak source levels of 100-110 dB re 1µPa with main frequencies ranging from 100 – 500 Hz have been reported (US Army Corps 2015). The noise generated by offshore mining operations thus falls within the hearing range of most fish and marine mammals, and would be audible for considerable ranges (in the order of tens of kms) before attenuating to below threshold levels. The extent of the noise impacts would, however, also depend on the variation in the background noise level with weather, wave action and with the proximity of other vessel traffic (not associated with the project).

Although not considered to be of sufficient amplitude to cause direct physical injury or mortality to marine life, even at close range, the underwater noise from mining operations may, however, induce localised behavioural changes or masking of biologically relevant sounds in some marine fauna, but there is no evidence of significant behavioural changes that may impact on the wider ecosystem (Perry 2005). In a study evaluating the potential effects of vessel-based diamond mining on the marine mammals community off the southern African West Coast, Findlay (1996) concluded that the significance of the impact is likely to be minimal based on the assumption that the radius of elevated noise level would be restricted to ~20 km around the mining vessel. The responses of cetaceans to noise sources are often also dependent on the perceived motion of the sound source as well as the nature of the sound itself. For example, many whales are more likely to tolerate a stationary source than they are one that is approaching them (Watkins 1986; Leung-Ng and Leung 2003), or are more likely to respond to a stimulus with a sudden onset than to one that is continuously present (Malme et al. 1985).

The impact of underwater noise generated during mining on marine fauna is considered to be of low intensity in the mining area and for the duration of the sampling/mining campaign. It is probable that underwater noise may mask biologically significant sounds, and disturbance and behavioural changes are possible. Sensitive receptors in the Mining Licence areas that may be influenced by underwater mining noise include seals from the colonies at Bucchu Twins (Sea Concession 1A) and Kleinzee (just south of Sea Concession 4A), resident odontocetes and diving seabirds roosting in the Orange River mouth wetlands. Cetaceans, turtles, large pelagic fish and pelagic seabirds associated with Child’s Bank (situated ~200 km south-southwest of Sea Concession 4B) and Tripp Seamount (situated ~250 km to the west southwest of the Sea Concession 1C) are unlikely to be affected by exploration and mining–related noise.

Noise impacts would, however, be fully reversible once mining operations are completed. The impact of underwater noise potentially masking biologically significant sounds is considered of VERY LOW significance without mitigation, whereas the impact of underwater noise resulting in avoidance of feeding and/or breeding area is considered INSIGNIFICANT without mitigation.

Mitigation Refer to Section 5.3.3.2. for mitigation of noise disturbance from geophysical surveying.

No mitigation is considered necessary for mining-generated underwater noise.

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Masking of biologically significant sounds in Marine Fauna due to noise from mining operations Without Mitigation Assuming Mitigation Extent Local: limited to mining site Duration Short-term: for duration of operations Intensity Low Probability Probable No mitigation is proposed Status Negative Confidence High Significance Very Low

Reversibility Fully reversible Mitigation Potential None

Impacts of noise from mining operations on Marine Fauna (Avoidance of feeding and/or breeding areas) Without Mitigation Assuming Mitigation Extent Local: limited to mining site Duration Short-term: for duration of operations Intensity Low Probability Possible No mitigation is proposed Status Negative Confidence High Significance Insignificant

Reversibility Fully reversible Mitigation Potential None

5.3.3.4 Disturbance and behavioural changes in Marine Fauna in Response to aircraft / helicopter noise

It is only the larger, remote mining vessels that will be operational in Sea Concessions 1B, 1C and 4B that may require crew changes via helicopter from either Alexander Bay or Kleinzee.

The dominant low-frequency components of aircraft engine noise (10-550 Hz) penetrate the water only in a narrow (26° for a smooth water surface) sound cone directly beneath the aircraft, with the angle of the cone increasing in Beaufort wind force >2 (Richardson et al. 1995). The peak sound level received underwater is inversely related to the altitude of the aircraft.

Available data indicate that the expected frequency range and dominant tones of sound produced by fixed-wing aircraft and helicopters overlap with the hearing capabilities of most odontocetes and mysticetes (Richardson et al. 1995; Ketten 1998). Determining the reactions of cetaceans to overflights is difficult, however, since most observations are made from either

Pisces Environmental Services (Pty) Ltd 125 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC the disturbing aircraft itself (Richardson and Würsig 1997), or from a small nearby vessel. Reactions to aircraft flyovers vary both within and between species, and range from no or minimal observable behavioural response (Belugas: Stewart et al. 1982, Richardson et al. 1991; Sperm: Clarke 1956, Gambell 1968, Green et al. 1992), to avoidance by diving, changes in direction or increased speed of movement away from the noise source (Gray: Withrow 1983; Belugas: Richardson et al. 1991, Patenaude et al. 2002; Sperm: Clarke 1956; Fritts et al. 1983, Mullin et al. 1991, Würsig et al. 1998; Minke: Leatherwood et al. 1982; Bowhead: Patenaude et al. 2002; Humpbacks: Smultea et al. 1995), separation of cow-calf pairs (Gray: Withrow 1983), increased surface intervals (Belugas: Awbrey & Stewart 1983; Stewart et al. 1982; Patenaude et al. 2002), changes in vocalisation (Sperm whales: Watkins and Schevill 1977, Richter et al. 2003, 2006) and dramatic behavioural changes including breaching and lobtailing (Minke: Leatherwood et al. 1982; Sperm: Fritts et al. 1983; Bowhead: Patenaude et al. 2002; Beluga: Patenaude et al. 2002), and active and tight clustering behaviour at the surface (Sperm: Smultea et al. 2008).

Most authors established that the reactions resulted from the animals presumably receiving both acoustic and visual cues (the aircraft and/or its shadow). As would be expected, sensitivity of whales to disturbance by an aircraft generally lessened with increasing distance, or if the flight path was off to the side and downwind, and if its shadow did not pass directly over the animals (Watkins 1981; Smultea et al. 2008). Smultea et al. (2008) concluded that the observed reactions of whales to brief overflights were short-term and isolated occurrences were probably of no long-term biological significance and Stewart et al. (1982) suggested that disturbance could be largely eliminated or minimised by avoiding flying directly over whales and by maintaining a flight altitude of at least 300 m. However, repeated or prolonged exposures to aircraft overflights have the potential to result in significant disturbance of biological functions, especially in important nursery, breeding or feeding areas (Richardson et al. 1995). Aircraft activities that might result in harassment of whales and longer-term effects include military training exercises, helicopter overflights associated with offshore oil and gas exploration and development, regular recreational/ecotourism flights and research surveys (Smultea et al. 2008). The level of disturbance would also depend on the distance and altitude of the aircraft from the animals (particularly the angle of incidence to the water surface) and the prevailing sea conditions. The nearest known calving and nursery sites are at Elizabeth Bay in Namibia ~230 km north of the Orange River mouth, and St Helena Bay ~360 km south of Kleinzee.

The reactions of pinnipeds to aircraft noise was reviewed by Richardson et al. (1995). As the frequency of aircraft engine noise overlaps with the hearing ranges of seals, these will likely similarly receive both acoustic and visual cues from aircraft flyovers. Richardson et al. (1995), however, point out that in very few cases was it determined that responses were specifically to aircraft noise as opposed to visual cues. Furthermore, most reported observations relate to pinnipeds on land or ice, with few data specifically on the reactions of pinnipeds in water to either airborne or waterborne sounds from aircraft. Reactions to flyovers vary between species, ranging from stampeding into the water, through temporary abandonment of pupping beaches to alertness at passing aircraft. When in the water, seals have been observed diving when the aircraft passes overhead. Pinnipeds thus exhibit varying intensities of a startle response to airborne noise, most appearing moderately tolerant to flyovers and habituating

Pisces Environmental Services (Pty) Ltd 126 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC over time (Richardson et al. 1995; Laws 2009). The rates of habituation also varies with species, populations, and demographics (age, sex). Any reactions to overflights would thus be short-term and isolated occurrences would unlikely be of any long-term biological significance. The Bucchu Twins seal colony in the surf zone opposite Sea Concession 1A potentially lies in the flight path of fixed-wing and helicopter operations if the Alexander Bay airfield is used as the logistics base. If the Kleinzee airfield is used for crew transfers to vessels operational in Sea Concession 4B, the flight path could potentially affect the seal colony at Kleinzee. Flight paths would need to be planned to avoid these colony. The colony at Strandfontein Point should not be affected.

The hazards of aircraft activity to birds include direct strikes as well as disturbance, the degree of which varies greatly. The negative effects of disturbance of birds by aircraft were reviewed by Drewitt (1999) and include loss of usable habitat, increased energy expenditure, reduced food intake and resting time and consequently impaired body condition, decreased breeding success and physiological changes. Nesting birds may also take flight and leave eggs and chicks unattended, thus affecting hatching success and recruitment success (Zonfrillo 1992). Differences in response to different types of aircraft have also been identified, with the disturbance effect of helicopters typically being higher than for fixed-wing aeroplanes. Results from a study of small aircraft flying over wader roosts in the German Wadden Sea showed that helicopters disturbed most often (in 100 % of all potentially disturbing situations), followed by jets (84 %), small civil aircraft (56 %) and motor-gliders (50 %) (Drewitt 1999).

Sensitivity of birds to aircraft disturbance are not only species specific, but generally lessened with increasing distance, or if the flight path was off to the side and downwind. However, the vertical and lateral distances that invoke a disturbance response vary widely, with habituation to the frequent loud noises of landing and departing aircraft without ill effects being reported for species such as gulls, lapwings, ospreys and starlings, amongst others (reviewed in Drewitt 1999). Further work is needed to examine the combined effects of visual and acoustic stimuli, as evidence suggests that in situations where background noise from natural sources (e.g. wind and surf) is continually high, the visual stimulus may have the greater effect. The nearest seabird colonies are at Elephant Rocks well to the south of the PSJV Sea Concession areas. The Orange River mouth wetlands, however, serve as an important habitat for a wide variety of waders and coastall birds, and flight paths would need to be planned to avoid this area.

Indiscriminate low altitude flights over whales, seals, seabird colonies and turtles by helicopters used to support the offshore mining vessels could thus have an impact on behaviour and breeding success. The level of disturbance would depend on the distance and altitude of the aircraft from the animals (particularly the angle of incidence to the water surface) and the prevailing sea conditions and could range from low to high intensity. Although such impacts would be localised and short term, impacts would be probable for low altitude flights and may thus have wider ramifications over the range of the affected species. As impacts would be fully reversible, the significance of the potential impact is considered to be of LOW significance without mitigation, and INSIGNIFICANT with mitigation.

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Mitigation The following mitigation measures are recommended to reduce and manage noise disturbance associated with helicopter operations:

 Implement relevant policies and proceedures to manage flight paths for helicopters.  Flight paths must be pre-planned to ensure that no flying occurs over coastal reserves (MacDougall’s Bay), seal colonies (Buchu Twins, Kleinzee and Strandfontein Point), bird colonies (Bird Island at Lambert’s Bay) or Important Bird Areas (Orange River Mouth wetlands).  Avoid extensive low-altitude coastal flights (<2,500 ft and within 1 nautical mile of the shore), particularly during the winter/spring (June to December) whale migration period and during the November to January seal breeding season.  The flight path between Alexander Bay / Kleinzee and mining vessel should be perpendicular to the coast.  Aircraft may not, without a permit or an exemption, approach to within 300 m of whales in terms of the Marine Living Resources Act, 1998, without a permit. As this may be both impractical and impossible, an exemption permit must be applied for through the Department of Environmental Affairs;  Contractors should comply fully with aviation and authority guidelines and rules;  Brief all pilots on the ecological risks associated with flying at a low level along the coast or above marine mammals.

Disturbance and behavioural changes in seabirds, seals, turtles and cetaceans due to support aircraft Without Mitigation Assuming Mitigation Extent Local: limited to immediate area around Local mining vessel Duration Short-term Short-term Intensity Low to High Low Probability Probable Possible Status Negative Negative Confidence High High Significance Low Insignificant

Reversibility Fully reversible Mitigation Potential Medium

5.2.4 Discharge of waste to sea (e.g. deck and machinery space drainage, sewage and galley wastes) and local reduction in water quality The project activities that will result in discharges of wastes to sea and local reductions in water quality in Licence 554MRC (Sea Concession 1A, 2A, 3A and 1B), Licence 512MRC (Sea Concession 4A), Licence 513MRC (Sea Area 4B), and Licence 10025MR (Sea Concession 1C) are described further below:

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Diver-Assisted Vessels

Small-scale contractors operating in the A-Concessions typically mine from converted fishing boats or purpose-built vessels of 10-15 m in length, although a few 20-22 m vessels are also operational. Mining operations are typically limited to daylight hours for 3-10 diving days per month when sea conditions are favourable. The smaller vessels return to port at night, whereas some of the larger vessels are able to work on a 24-hour basis and can thus stay at sea for longer. Onboard facilities on these vessels are limited and in most cases they are not MARPOL compliant, with deck drainage, sewage and galley wastes being discharged overboard. On certain of the smaller mining vessels sewage is held in a header tank prior to dilution with seawater and discharge. Sewage from vessels without header tanks is discharged directly overboard.

Remote Mining Vessels

The mid- and deep-water vessels in contrast range from 1,000 - 6,000 gross registered tons, and up to 150 m in length. These ships are fully self-contained mining units, with a processing facility on board, potentially able to operate 24-hours a day for 11 months of the year. Discharges from these vessels are described below:

 Deck drainage: all deck drainage from work spaces is collected and piped into a sump tank on board the mining vessels to ensure MARPOL compliance (15 ppm oil in water). The fluid would be analysed and any hydrocarbons skimmed off the top prior to discharge. The oily substances would be added to the waste (oil) lubricants and disposed of on land.  Sewage: sewage discharges will be comminuted and disinfected. In accordance with MARPOL Annex IV, the effluent must not produce visible floating solids in, nor causes discolouration of, the surrounding water. The treatment system must provide primary settling, chlorination and dechlorination before the treated effluent can be discharged into the sea. The discharge depth is variable, depending upon the draught of the mining vessels at the time, but would not be less than 5 m below the surface.  Vessel machinery spaces and ballast water: the concentration of oil in discharge water from vessel machinery space or ballast tanks may not exceed 15 ppm oil in water (MARPOL Annex I). If the vessel intends to discharge bilge or ballast water at sea, this is achieved through use of an oily-water separation system. Oily waste substances must be shipped to land for treatment and disposal.  Food (galley) wastes: food wastes may be discharged after they have been passed through a comminuter or grinder, and when the mining vessels is located more than 3 nautical miles from land. Discharge of food wastes not comminuted is permitted beyond 12 nautical miles. The ground wastes must be capable of passing through a screen with openings <25 mm. The daily volume of discharge from a standard offshore mining vessels is expected to be <0.5 m3.  Detergents: detergents used for washing exposed marine deck spaces are discharged overboard. The toxicity of detergents varies greatly depending on their composition, but low-toxicity, biodegradable detergents are preferentially used. Those used on work deck spaces would be collected with the deck drainage and treated as described above.

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 Cooling Water: electrical generation on mining vessels is typically provided by large diesel-fired engines and generators, which are cooled by pumping water through a set of heat exchangers. The cooling water is then discharged overboard. Other equipment is cooled through a closed loop system, which may use chlorine as a disinfectant. Such water would be tested prior to discharge and would comply with relevant Water Quality Guidelines.

Impact description and assessment The discharge of wastes to sea from mining vessels operational in Licence 554MRC (Sea Concession 1A, 2A, 3A and 1B), Licence 512MRC (Sea Concession 4A), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C), has the potential to create local reductions in water quality, both during transit and at the mining site. The potential impact of such operational discharges from the mining vessels would include reduced physiological functioning of marine organisms due to the biochemical effects on the water column, increased food source for marine fauna due to discharge of galley wastes potentially leading to fish aggregation around drilling units and increased predator-prey interactions. Waste discharges are expected to disperse rapidly and there is no potential for accumulation of wastes leading to any detectable long-term impact.

The majority of the discharged wastes are not unique to the project vessels, but rather common to the numerous vessels (mainly fishing) that operate in or pass through southern African coastal waters daily. As volumes discharged would be low, any associated impacts would be of low intensity and limited to the mining location over the short-term. Although waste discharges would definitely occur as a result of the operation of the mining vessels, for the nearshore diver assisted vessels that are typically not MARPOL compliant, the likelihood of impacts occurring is considered to be ‘definite’ but with the impacts remaining highly localised over the very short term. This impact is considered to be fully reversible as waste discharges and the potential impact would cease after mining in an area has been completed. The significance of the potential impacts is therefore considered to be VERY LOW without and with mitigation. For the larger offshore drill ships and crawler vesssels, which are mostly MARPOL compliant, the likelihood of the impact occurring is ‘probable’, with impacts remaining highly localised for as long as the vessel is in the area. The significance of the potential impacts for the remote mining vessels is therefore considered to be VERY LOW without and with mitigation and INSIGNIFICANT with mitigation.

Mitigation The following mitigation measures are recommended:

General

 Develop and implement a waste management system for ALL mining vessels that addresses all wastes generated at the various sites: nearshore and offshore. This should include:  Separation of wastes at source;  Recycling and re-use of wastes where possible;

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Diver-assisted vessels

 All wastes (including galley wastes) generated by the shallow-water diver-assisted operations must be returned to shore for disposal at a licenced waste disposal site.

 Ensure that all mining vessels that stay out overnight have sewage holding tanks, and that sewage is diluted with seawater prior to discharge. Vessels too small for holder tanks should consider installing chemical toilets.

Remote mining vessels

 Ensure compliance with MARPOL 73/78 standards,

 Treatment of wastes at source (maceration of food wastes, compaction, incineration, treatment/storage of sewage and oily water separation).

 If wastes are incinerated on board ensure that an Atmospheric Emissions Licence is in place.

 All hazardous wastes must be brought to shore for disposal at a licenced hazardous waste site.

 Dechlorinate sewage effluents and cooling water to World Bank standards for residual chlorine (0.2 mg/ℓ at the point of discharge prior to dilution).

 Prepare and implement a Shipboard Oil Pollution Emergency Plan.

Impacts of operational discharges to the sea from nearshore diver-assisted mining vessels Without Mitigation Assuming Mitigation Extent Local: limited to immediate area around Local vessel Duration Short-term Short-term Intensity Low Low Probability Definite Probable Status Negative Negative Confidence High High Significance Very Low Very Low

Reversibility Fully reversible Mitigation Potential Low

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Impacts of operational discharges to the sea from deep-water remote mining vessels Without Mitigation Assuming Mitigation Extent Local: limited to immediate area around Local drill unit or support vessel Duration Short-term Short-term Intensity Low Very Low Probability Probable Possible Status Negative Negative Confidence High High Significance Very Low Insignificant

Reversibility Fully reversible Mitigation Potential Low

5.2.5 Potential loss and discard of equipment The project activities that may result in equipment loss are described further below:

 Shore-based contractors operational in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A opposite Farm 1 and Farm 155) typically establish campsites and storage areas for vehicles, tractors and heavy equipment. Mining infrastructure and equipment are often left on site following completion of mining operations in an area, or if the equipment becomes derelict.

 Vessel-based diver-mining contractors operating in Licence 554MRC (Sea Concession 1A, 2A and 3A) and Licence 512MRC (Sea Concession 4A) may mark current mining sites with buoys, which may be subsequently left in place thereby providing entanglement hazards over the very short term. Equipment such as anchors and mining tools may occasionally be lost on the seabed.

 Larger vessels test-mining and mining in Licence 554MRC (Sea Concession 1B), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C), may similarly occasionally lose anchors and mining tools on the seabed. Due to the size and cost of this hardware every effort is usually made to retrieve them. Materials and supplies may also be transported by supply vessels to mining vessels. As with any transfer operation there is a risk of dropped objects. Dropped objects may include drums / containers of oil, fuel, chemicals, paint, sacks, pallets, equipment, skips, garbage, etc.

Impact description and assessment If left on the seabed, large items such as anchors and mining tools could form a hazard to other users. Buoyed cables and ropes pose an entanglement hazard to marine mammals and turtles and could lead to drowning of these animals. Although the weight of biofouling would sink the floating structures in the short-term, every effort should be made to remove foreign objects from the water column. Anchors and mining tools left on the seabed would effectively increase the availability of hard substrate for colonisation by sessile benthic organisms, thereby

Pisces Environmental Services (Pty) Ltd 132 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC locally altering community structure and increasing biodiversity and biomass. This may have positive implications to certain fish species (e.g. kingklip Genypterus capensis and jacopever Helicolenus dactylopterus, which show a preference for structural seabed features). Equipment abandoned in the coastal zone primarily causes an aesthetic impact.

The increase in biodiversity (neutral impact) due to the presence of abandoned subsea structures would be considered a secondary impact of very low intensity. The impact is highly localised but would be permanent if the equipment is left on the seafloor. The impact is considered to be of VERY LOW significance without mitigation and INSIGNIFICANT with mitigation. For ropes and cables discarded in the water column, the impact would be of medium intensity over the short-term and similarly be of LOW significance without mitigation and INSIGNIFICANT with mitigation.

Mitigation The following measures are recommended to reduce and manage the accidental loss of equipment:

 Remove all derelict and abandoned equipment in the coastal zone and dispose of at a licenced landfill site and/or recycle.

 Remove marker buoys once a mining block has been completed.

 Establishing an offshore hazards database listing the type of gear left on the seabed and/or in the licence area with the dates of abandonment/loss and locations, and where applicable, the dates of retrieval.

 As far as possible retrieve any lost equipment.

Impacts of lost equipment on marine biodiversity Without Mitigation Assuming Mitigation Extent Local: limited to loss site Local Duration Permanent Short-term Intensity Very Low Very Low Probability Probable Possible Status Neutral Neutral Confidence Medium Medium Significance Very Low Insignificant

Reversibility Fully reversible Mitigation Potential Medium

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Potential entanglement impacts of ropes and cable discarded in the water column Without Mitigation Assuming Mitigation Extent Local: limited to discard site Local Duration Short-term Short-term Intensity Medium Very Low Probability Probable Improbable Status Negative Negative Confidence Medium Medium Significance Very Low Insignificant

Reversibility Fully reversible Mitigation Potential High

5.2.6 Increased Ambient Lighting The project activities that will result in an increase in ambient lighting are described further below:

 Transit and operation of the drill ships and crawler vessels, and any potential support vessels. The operational lighting of sampling and mining vessels operational in Licence 554MRC (Sea Concession 1B), Licence 513MRC (Sea Concession 4B), and Licence 10025MR (Sea Concession 1C) can be a significant source of artificial light in the offshore environment. Note: smaller mining vessels typically return to port at night.

Impact description and assessment The strong operational lighting used to illuminate the offshore mining vessels at night in will increase the ambient lighting in offshore areas thereby potentially disturbing and disorientating pelagic seabirds feeding in the area. Operational lights may also result in physiological and behavioural effects of fish and cephalopods as these may be drawn to the lights at night where they may be more easily preyed upon by other fish and seabirds.

Most of the seabird species along the West Coast feed relatively close inshore (10-30 km). Cape gannets, however, are known to forage up to 140 km offshore (Dundee, 2006; Ludynia, 2007). However, the nearest nesting ground for Cape Gannets is at Bird Island in Lambert’s Bay, which is ~300 km to the south of the concessions areas. Most of the pelagic seabird species in the region reach highest densities offshore of the shelf break (200 to 500 m depth), which is offshore of the concession areas. As all Sea Concessions fall within 30 km of the coast, encounters with seabirds are highly likely.

Although little can be done on mining vessels to prevent seabird collisions, reports of collisions or death of seabirds on mining vessels are rare. It is expected that seabirds and marine mammals in the area become accustomed to the presence of the mining vessels within a few days, thereby making the significance of the overall impact on these populations negligible.

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The significance to the populations of fish and squid of increased predation as result of being attracted to an installation’s lights is deemed to be insignificant.

Seals are highly mobile animals with a general foraging area covering the continental shelf up to 120 nm (approximately 220 km) offshore. Since the Bucchu Twins seal colony occurs within Sea Concession 1a, numbers can be expected to be high.

The increase in ambient lighting in the offshore environment would be of very low intensity and limited to the mining site over the short-term. Although an increase in ambient lighting would definitely occur as a result of the operation of the mining vessels, the likelihood of impacts occurring is considered to be ‘possible’. This impact is considered to be fully reversible. The significance of the potential impacts is therefore considered to be INSIGNIFICANT with and without mitigation.

Mitigation The following measures are recommended to reduce and manage increased ambient lighting from the mining vessels:

 Minimise non-essential lighting on all vessels to reduce nocturnal attraction

 Where feasible, shielding operational lights in such a way as to minimise their spill out to sea

 Record information on patterns of bird reaction to lights and real incidents of injury/death, including stray land birds resting on the vessel, during the mining operation

 Keep disorientated, but otherwise unharmed, seabirds in dark containers for subsequent release during daylight hours. Injured birds should be humanely euthanised. Ringed/banded birds should be reported to the appropriate ringing/banding scheme (details are provided on the ring).

Impacts of increased ambient lighting from mining vessels

Without Mitigation Assuming Mitigation Extent Local: limited to immediate area around Local drill unit or support vessel Duration Short-term Short-term Intensity Very Low Very Low Probability Possible Possible Status Negative Negative Confidence High High Significance Insignificant Insignificant

Reversibility Fully reversible Mitigation Potential Low

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5.2.7 Accidents and Emergencies The project activities that may result in a vessel accident or operational spills are described further below:

 Instantaneous spills of marine diesel and/or hydraulic fluid in the intertidal zone or at the surface of the sea can potentially occur in all licence areas and during all project activity phases, both from the shore-based operations or from mining vessels. Such spills are usually of a low volume and occur accidentally during fuel bunkering or as a result of hydraulic pipe leaks or ruptures.  Shore-based contractors operational in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A opposite Farm 1 and Farm 155) typically establish campsites to provide on-site accommodation and shelter. Mining infrastructure and equipment are stored and parked above the high water mark where accidental spills may occur during refuelling, or leaks may develop as a consequence of poor maintenance and neglect.

 Sampling and test mining operations in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A opposite Farm 1 and Farm 155) by ‘walk-in’ jack-up may result in accidental damage to or wreckage of the platform during high seas, or operational spills during sampling activities.

 Larger volume spills of marine diesel would occur in the event of a vessel collision or vessel accident either during transit or during operation in Licence 554MRC (Sea Concessions 1A, 2A, 3A and 1B), Licence 513MRC (Sea Concessions 4A and 4B), and Licence 10025MR (Sea Concession 1C).

Impact description and assessment Operational spills from vessels

Operational spills may arise from bunkering of fuel oil (offshore or in port), the storage and handling of oil drums or faults in the oil/water separator and the vessel drainage system. Operational spills from vessels would involve either fuel or lube oils. Grounding or sinking of a vessel, accidental and/or operational oil spills from the vessel, or whilst refuelling with marine diesel oil, would have an immediate detrimental effect on water quality, with the toxic effects potentially resulting in mortality (e.g. suffocation and poisoning) of marine fauna or affecting faunal health (e.g. respiratory damage). Pollution by oil poses a great risk for many marine organisms, and specifically for the African penguin. The impact of oiling not only results in the death of oiled birds, but also has cascade effects through the entire population by decreasing the breeding success. Oil pollution thus represents a significant threat to the seabird population and may contribute to some of the endangered species becoming extinct in the wild. The nearest nesting ground for Cape Gannets is at Bird Island in Lambert’s Bay, while the nearest African Penguins nesting sites are at the Saldanha Bay Islands and Dassen Island. As these are all extended distances from the mining areas, the likelihood of these seabird species being present in the mining right area in large numbers is extremely low. Numerous cormorant species are, however, present in the Orange River mouth wetlands and may be affected by an operational spill from vessels.

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The consequences and effects of small (2,000 - 20,000 litres) diesel fuel spills into the marine environment are summarised below (NOAA 1998). Diesel is a light oil that, when spilled on water, spreads very quickly to a thin film and evaporates or naturally disperses within a few days or less, even in cold water. Diesel oil can be physically mixed into the water column by wave action, where it adheres to fine-grained suspended sediments, which can subsequently settle out on the seafloor. As it is not very sticky or viscous, diesel is washed off surfaces quickly by waves and tidal flushing. In the case of a spill, shoreline cleanup is thus usually not needed. Diesel oil is degraded by naturally occurring microbes within one to two months. Nonetheless, in terms of toxicity to marine organisms, diesel is considered to be one of the most acutely toxic oil types. Many of the compounds in petroleum products are known to smother organisms, lower fertility and cause disease. In the case of a vessel wreckage on the shore, intertidal invertebrates and seaweed that come in direct contact with the diesel spill may suffer mortality. Fish mortality, however, have never been reported for small spills in open water as the diesel dilutes so rapidly. Due to differential uptake and elimination rates, filter-feeders (particularly mussels) can bio-accumulate hydrocarbon contaminants. Crabs and shellfish can be tainted from small diesel spills in shallow, nearshore areas. Small diesel spills can also affect marine birds by direct contact.

The larger remote mining vessels carry in the order of 1,000 m3 of marine diesel, so under the worse-case scenario of a vessel grounding or sinking, in the order of 800,000 litres could be lost to the marine environment. The results of an oilspill modelling study undertaken for an 87 ton (~74,000 litres) operational spill at 130 m depth and ~ 50 km offshore of the Holgat River (PRDW 2014) identified that the spill would travel about 95 km from the source in a northwesterly direction, but that there was minimal chance of the diesel reaching the shoreline. The intensity of the potential impact of an operational spill of this size varies depending on the faunal group affected, ranging from zero for benthic macrofauna, low for pelagic fish and larvae, marine mammals and turtles, to high for seabirds, persisting only over the short-term (days).

If a spill occurs in port while bunkering/loading the impact would most likely be easily managed and the risk / impact would be low. Similarly, operational spills or grounding and sinking of a diver-assisted mining vessel would involve low volumes of marine diesel, which would be rapidly dispersed along the wave exposed coastline.

The significance of the impact of an operational spill is dependent on the biota likely to be affected and where the spill occurs. In most cases the impacts can be considered of VERY LOW to LOW significance before mitigation, with the exception of seabirds, where the impact is considered to be of LOW significance before mitigation. Should they occur, impacts would be fully reversible. All impacts are considered to be INSIGNIFICANT with mitigation.

Operational spills onshore

Onshore spills are likely to be of a low volume and occurring accidentally during refuelling of machinery or as a result of hydraulic pipe leaks or ruptures as a consequence of poor maintenance and neglect. As diesel tends to penetrate porous sediments quickly, spills in the supratidal and intertidal area would result in soil contamination. However, if spilled in the rocky intertidal, it would be washed off quickly by waves and tidal flushing as it is not very

Pisces Environmental Services (Pty) Ltd 137 MARINE and COASTAL ECOLOGY – EMPR Amendment for Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC sticky or viscous. Although degraded by naturally occurring microbes within one to two months diesel oil is considered to be acutely toxic to marine organisms, diesel. Consequently, intertidal invertebrates and seaweed that come in direct contact with a diesel spill may be killed.

A highly localised operational spill in the supratidal and intertidal would thus be of medium to high intensity in the short term. Small operational spills onshore are considered highly probably, but in most cases the impacts on biota can be considered of LOW significance before mitigation, reducing to INSIGNIFICANT with mitigation. Should they occur, impacts would be fully reversible.

Mitigation The following mitigation measures are recommended:

 Seek to reduce the probabilities of accidental and/or operational spills through enforcement of stringent oil spill management systems. These should incorporate plans for emergencies and Environmental Awareness and Spill Training to ensure the contractors and their staff are appropriately informed of how to deal with spills.  Ensure good housekeeping practices are in place at all shore-based operations. This should include :  Place drip trays under all stationary machinery,  Bunding of all fuel storage areas,  Restrict vehicle maintenance to the maintenance yard area, except in emergencies when the beach area may be used if absolutely necessary  Maintain mining equipment to ensure that no oils, diesel, fuel or hydraulic fluids are spilled  Refuelling must occur under controlled conditions, and (for vessels) in a harbour only.

Impacts of an operational spill on intertidal and subtidal benthic macrofauna Without Mitigation Assuming Mitigation Extent Local Local Duration Short-term Short-term Intensity Medium to High (Low for offshore) Very Low Probability Improbable (offshore and nearshore) – Improbable Probable (onshore) Status Negative Negative Confidence High High Significance Very Low (offshore) –Low (nearshore and Insignificant onshore)

Reversibility Fully reversible Mitigation Potential Medium

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Impacts of an operational spill on pelagic fish and larvae Without Mitigation Assuming Mitigation Extent Local Local Duration Short-term Short-term Intensity Low Low Probability Probable Possible Status Negative Negative Confidence High High Significance Very Low Insignificant

Reversibility Fully reversible Mitigation Potential Low

Impacts of an operational spill on seabirds Without Mitigation Assuming Mitigation Extent Local Local Duration Short-term Short-term Intensity High Medium Probability Probable Possible Status Negative Negative Confidence High High Significance Low Insignificant

Reversibility Fully reversible Mitigation Potential Medium

Impacts of an operational spill marine mammals and turtles Without Mitigation Assuming Mitigation Extent Local Local Duration Short-term Short-term Intensity Low Low Probability Probable Possible Status Negative Negative Confidence High High Significance Very Low Insignificant

Reversibility Fully reversible Mitigation Potential Low

5.2.8 Cumulative Impacts The primary impacts associated with mining of marine diamonds in the Namaqua Bioregion on the West Coast of South Africa, relate to physical disturbance of the seabed, discharges of

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Although the areas of seabed targeted for mining amounts to only a fraction of the total respective PSJV surf zone and sea Concessions (1C = 1%, 1B = 3%, 1A, 2A, 3A = 2%, surf zone opposite Farm 1 and Farm 155 = <10%) the cumulative impact of years of mining by an increasing number of contractors applying progressively modern techniques to locate and access diamond deposits must be kept in mind. Considering the prevalence of endangered and critically endangered habitat types in the mining licence areas and the decades of uncontrolled and environmentally irresponsible operations these cumulative impacts are considered to be of MEDIUM significance. Detailed records of annual and cumulative areas sampled and mined should be maintained, and submitted to the authorities should future informed decisions need to be made regarding disturbance limits to benthic habitat types in the Namaqua Bioregion.

Cumulative impacts to the benthic environment also include the development of hydrocarbon wells. Since 1976 ~40 wells have been drilled in the Namaqua Bioregion. The majority of these occur in the iBhubesi Gas field in Block 2A well to the south and offshore of the PSJV concessions. Prior to 1983, technology was not available to remove wellheads from the seafloor. Of the approximately 40 wells drilled on the West Coast, 35 wellheads remain on the seabed. The total area impacted by 40 petroleum exploration wells is estimated at around 10 km2, or ~0.038 % of the Namaqua bioregion. Cumulative impacts from other hydrocarbon ventures in the area are likely to increase in future, particularly with the planned development of the iBhubesi Gas Field. Further exploratory drilling has also being proposed in Block 1 and Block 2B.

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6. CONCLUSIONS The impacts on marine habitats and communities associated with the proposed mining for marine diamonds in Licence 554MRC (the surf zones and shallow portions of Sea Concessions 1A, 2A and 3A), Licence 513MRC (Sea Concessions 4A and 4B), and Licence 10025MR (Sea Concession 1C) are summarised in the Table below (Note: * indicates that no mitigation is possible, thus significance rating remains).

Significance Significance Impact (before mitigation) (after mitigation) Disturbance and loss of supratidal habitats and associated High Medium biota Disturbance and loss of rocky intertidal and shallow subtidal Medium to High Very Low biota by shore-based diver operations Disturbance and loss of intertidal and shallow subtidal sandy Low Very Low beach macrofauna by shore-based diver operations Destruction and loss of intertidal and shallow subtidal Very Low Very Low* macrofauna by ‘walk-in’ platforms High (beaches) to Medium (beaches) to Destruction and loss of intertidal and shallow subtidal biota by Very High (rocky High (rocky shores) cofferdam operations shores) Medium to High Low Disturbance and loss of nearshore biota by diver-assisted (critically operations endangered habitats) Medium to High Low Disturbance and loss of biota in offshore unconsolidated (critically sediments endangered habitats) Crushing of benthic fauna by crawler and anchors Very Low Very Low* High to Very High Low Smothering of highshore communities and alteration of habitat (critically by discarded tailings endangered habitats) Low to Medium Very Low Smothering of intertidal and nearshore reef communities and (critically alteration of habitat by discharged tailings endangered habitats) Smothering of macrofauna in offshore (>5 m) unconsolidated Very Low (inshore) Very Low sediments and alteration of habitats by discharged tailings to Low (offshore) Smothering of deep-water rocky outcrop communities by Very Low Insignificant discharged tailings Impacts of tailings discharge on water column and bottom- Insignificant Insignificant* water biochemistry (turbidity and light) Impacts of sediments eroded from cofferdam walls on water Medium Medium* column and bottom-water biochemistry (turbidity and light)

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Significance Significance Impact (before mitigation) (after mitigation) Indirect Impacts of tailings discharges: development of anoxic Insignificant Insignificant* sediments Biochemical Impacts of heavy metals in tailings on marine Insignificant Insignificant* organisms Physiological injury in Marine Fauna due to noise from Very Low Insignificant geophysical surveys Behavioural changes and masking of biologically significant Very Low Very Low* sounds in Marine Fauna due to noise from mining operations Impacts of noise from mining operations on Marine Fauna Insignificant Insignificant* (Avoidance of feeding and/or breeding Concessions) Disturbance and behavioural changes in seabirds, seals, turtles Low Insignificant and cetaceans due to support aircraft Impacts of operational discharges to the sea from nearshore Very Low Very Low diver-assisted mining vessels Impacts of operational discharges to the sea from deep-water Very Low Insignificant remote mining vessels Impacts of lost equipment on marine biodiversity Very Low Insignificant Potential entanglement impacts of ropes and cable discarded Very Low Insignificant in the water column Impacts of increased ambient lighting from mining vessels Insignificant Insignificant* Very Low (offshore) Insignificant Impacts of an operational spill on intertidal and subtidal – Low (nearshore benthic macrofauna and onshore) Impacts of an operational spill on pelagic fish and larvae Very Low Insignificant Impacts of an operational spill on seabirds Low Insignificant Impacts of an operational spill marine mammals and turtles Very Low Insignificant

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7. MITIGATIONS AND MANAGEMENT PLAN

Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

1. PROSPECTING PHASE

1.1 Stakeholder Minimise disruption  Notify relevant government departments and other key stakeholders of the commencement of Contractor 14 days prior Copies of all prospecting or mining operations (including navigational co-ordinates, timing and duration of Notification of other marine to start correspondence proposed activities) and the restrictions related to the operation. Stakeholders include: users / activities  Fishing industry / associations;  Local fishing operators;  SAN Hydrographic office. 1.2 Geophysical Minimise noise  Onboard Marine Mammal Observers (MMOs) should conduct visual scans for the presence of Contractor For duration MMO reports cetaceans around the survey vessel prior to the initiation of any acoustic impulses. Surveying impacts on marine of  Pre-survey scans should be limited to 15 minutes prior to the start of survey equipment. fauna geophysical  “Soft starts” should be carried out for any equipment of source levels greater than 210 dB re 1 surveys μPa at 1 m over a period of 20 minutes to give adequate time for marine mammals to leave the vicinity.  Terminate the survey if any marine mammals show affected behaviour within 500 m of the survey vessel or equipment until the mammal has vacated the area.  Avoid planning geophysical surveys during the movement of migratory cetaceans (particularly baleen whales) from their southern feeding grounds into low latitude waters (beginning of June to end of November), and ensure that migration paths are not blocked by sonar operations. As no seasonal patterns of abundance are known for odontocetes occupying the proposed exploration area, a precautionary approach to avoiding impacts throughout the year is recommended.  Ensure that PAM (passive acoustic monitoring) is incorporated into any surveying taking place between June and November.  A MMO should be appointed to ensure compliance with mitigation measures during seismic geophysical surveying.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

1.3 Geophysical Minimise  Ensure compliance with MARPOL 73/78 standards, Vessel operator Ongoing  Develop and implement a waste management system for ALL mining vessels that addresses all Surveying operational wastes generated at the various sites. This should include: discharges from  Separation of wastes at source; diver-assisted  Recycling and re-use of wastes where possible. vessels  All wastes (including galley wates) must be returned to shore for disposal at a licenced waste disposal site.  Ensure that all mining vessels that stay out overnight have sewage holding tanks, and that sewage is diluted with seawater prior to discharge. Vessels too small for holder tanks should consider installing chemical toilets. 1.4 Geophysical Minimise  Ensure compliance with MARPOL 73/78 standards, Vessel operator Ongoing  Develop and implement a waste management system for ALL mining vessels that addresses all Surveying operational wastes generated at the various sites. This should include: discharges from  Separation of wastes at source; remote mining  Recycling and re-use of wastes where possible; vessels  Treatment of wastes at source (maceration of food wastes, compaction, incineration, treatment/storage of sewage and oily water separation).  If wastes are incinerated on board ensure that an Atmospheric Emissions Licence is in place.  All hazardous wastes must be brought to shore for licenced disposal  Dechlorinate sewage effluents and cooling water to World Bank standards for residual chlorine. 1.5 Sampling and Minimise impacts on  Use should be made of existing geophysical data to conduct a pre-mining geohazard analysis of Mine planner Ongoing the seabed, and near-surface substratum to map potentially vulnerable habitats and prevent Test Mining rocky outcrop potential conflict with the mining targets. The SANBI benthic habitat maps should be communities incorporated into the company’s GIS mapping so as to identify potential overlap of current and future mining targets with endangered and critically endangered habitats. This information should be included in the ECOP for contractors.  Avoid targeting areas of unconsolidated sediments in close proximity to rocky outcrop areas identified by the pre-mining geohazard seabed analysis. This should include a suitable buffer zone around identified sensitive areas to ensure that these are not affected indirectly by plume impacts.  Operate ‘walk-in’ platforms in sandy bays only to avoid damage of shallow water reefs and their associated kelp-bed communities. (This is primarily an operational constraint due to the difficulty of controlling stable leg positions in uneven rocky terrain).

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

1.6 Environmental Demonstrate natural  Before the commencement of new mining approaches develop a well-structured monitoring Environmental Before start programme the principal objective of which is to demonstrate natural recovery processes by Monitoring recovery processes Manager of operations means of pre- and post-mining seabed and benthic faunal community surveys. Pre-mining baseline data should be collected in areas where mining activities are planned and changes in the benthic community structures in impacted areas should be regularly assessed.  Ensure the provision of adequate resources to implement monitoring surveys. 1.7 Planning for Optimising the post  Ensure that plans for rehabilitation, and provision of resources to achieve these, form an Environmental Before start integral part of mining planning from start-up. This should include: Closure mining land/seabed Manager of operations  Identify all necessary guidelines for mitigation of negative effects including the removal of use potential abandoned equipment and garbage, minimisation of air and water pollution, tailings/ soil handling, re-establishment of benthos/ vegetation,  Plan for the demolition and/or removal of all structures and debris on cessation of mining activities, and the restoration of the land surface above HWM as per guidelines herein.  Clearly allocate timing and responsibility for rehabilitation to mine operators and/or contractors.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

2. OPERATIONAL PHASE: Shore-based diver-assisted mining

2.1 Environmental Raise awareness in  An Environmental Code of Operational Practice (ECOP) must be prepared for each contractor. Environmental Ongoing The ECOP will be specific to each operational area and will include Responsibility contractors Manager/Contr  Environmental considerations (i.e. identification of sensitive receptors) and establishment actor Manager of no-go / restricted areas  Site location and demarcation of the extent of the campsite and processing area, and access routes  Housing keeping:  Use of drip trays under stationary plant and for refuelling and maintenance activities  Use and maintenance of toilet facilities  Bunding of fuel stores  Demarcation of refuelling and maintenance areas  Waste management, including the removal of all facilities, waste and other features established during mining activities  Rehabilitation specification (if necessary), e.g. topsoil management, reshaping, netting, etc.  Establishment of a rehabilitation fund  Monitoring  Before the commencement of any work on site, the contractor's site staff must attend an environmental awareness-training course presented by the Manager/Officer. The contractor must keep records of all environmental training sessions, including names of attendees, dates of their attendance and the information presented to them. 2.2 Roads Avoid use of  Use only established informal tracks to access existing mining sites, avoiding the creation of Environmental Ongoing new tracks or the use of ‘short-cuts’ as far as possible. If a mining site is moved along the coast unnecessary tracks Manager/Contr within a concession block and access is required along the coast, this should be undertaken actor Manager below the HWM when on sandy / beach area.  Identify and map the required existing tracks and develop a maintenance and rehabilitation program that ensures that necessary tracks are maintained. Permitted tracks are to be marked as such and all duplicate tracks leading to mining sites should be closed and rehabilitated.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

2.3 Campsites and Avoid damage to  Use existing infrastructure where possible. Environmental Ongoing  If a new camp is required the following guidelines apply: Parking Areas and disturbance of Manager/Contr  Select an area which is already disturbed thereby minimising further damage natural coastal zone actor Manager vegetation.  Do not establish camps within 100 m of the edge of a river channel or estuary.  Avoid sensitive areas, such as coastal dunes.  Avoid sites on prominent raised areas where a visual impact may result.  Limit the campsite and equipment storage area to the minimum reasonably required and to that which will cause least disturbance to the vegetation and natural environment.  Provide adequate kitchen and ablution (portable chemical toilets) facilities.  Restrict fires/braais to properly constructed facilities and provide firewood.  Ensure good housekeeping practices are in place at all shore-based operations. This should include :  Place drip trays under all stationary machinery,  Bunding of all fuel storage areas,  Restrict vehicle maintenance to the maintenance yard area, except in emergencies when the beach area may be used if absolutely necessary,  Maintain mining equipment to ensure that no oils, diesel, fuel or hydraulic fluids are spilled  Refueling is to occur under controlled conditions only.  Seek to reduce the probabilities of accidental and/or operational spills through enforcement of stringent oil spill management systems. These should incorporate plans for emergencies.  On completion of operations at a mine site, remove all facilities, waste and other features established during mining activities or for accessing a mining site.  Clean up and remove discarded equipment, or abandoned structures as part of responsible environmental management in new or renewed operations. 2.4 Plant collecting Management of  Do not collect any plants within the mining area Environmental Ongoing resources Manager/Contr actor Manager

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

2.5 Access to Minimise intertidal  Mining of any nature should not be permitted in intertidal and shallow subtidal habitats identified Environmental Ongoing as critically endangered (Namaqua Sheltered Rocky Coast) by the SANBI’s National Mining Site impacts Manager/Contr Biodiversity Assessment (Sink et al. 2011). If, however, prospecting / mining is proposed within actor Manager this area an independent assessment of the habitats and associated biota should be undertaken by a suitably qualified ecologist to verify the habitat status. Should it be confirmed that the habitats are in deed ecologically unique, these areas should be declared ‘no-go’ / restrictedareas and any operations there should be prohibited.  Restrict mining within the endangered Namaqua Mixed Shore habitat, which are represented by more extensive areas off the West Coast, to less than 1% of the available habitat within the Mining Licence Area annually. unless the habitat is confirmed to be different by a suitably qualified ecologist.  Limit the processing area to the minimum reasonably required and to that which will cause least disturbance to the vegetation and natural environment. The extent of the sites should be clearly demarcated (e.g. with droppers).  Prohibit blasting of rocky intertidal habitats and investigate alternative options to create the required access to the low water mark.  Conserve natural ecological zonation patterns in the inter-tidal and shallow sub-tidal by not significantly altering natural rock distributions through the use of explosives, machinery, e.g. back-actors, or other excavation systems.  Limit the removal of boulders in the mining target. If re-location of boulders is necessary these should not be removed to higher tidal levels, or accumulated in rock piles, but distributed evenly across the shore. 2.6 Mineral Facilitate natural  During diver operations, classifiers used by shore-based contractors must be located as far Environmental Ongoing down the intertidal as possible to facilitate the natural redistribution of course tailings by wave Processing and recovery Manager/Contr action, but definitely below the high water mark. If tailings heaps have been or are created on tailings actor Manager the high shore, the material must be removed on a regular basis and re-used for other discharge applications (e.g. dust control around buildings and processing plants, construction of cofferdams).  If tailings heaps are created on the high shore, the material must be removed on a regular basis and re-used for other applications (e.g. dust control around buildings and processing plants, construction of cofferdams).  Confine stockpiles and processing of ore to mineral processing areas and limit the separation process to a specific controlled area.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

2.7 Kelp cutting Minimise subtidal  Do not cut kelp unless diver safety is at stake, or it is essential for the operation. Environmental Ongoing  Do not remove the entire plant but cut the kelp stipes just above the holdfast. impacts Manager/Contr  Where extensive kelp cutting is required, notify relevant kelp harvesting permit holders to collect actor Manager the cut kelp. 2.8 Generation of Prevent littering and  Ensure that all solid wastes generated at the campsite and mineral processing area are disposed of in relevant containers and that these be regularly removed to a recognised waste Wastes accumulation of disposal site solid wastes 2.9 Recreational Management of  Do not collect any shellfish (including abalone, rock lobster, mussels) or undertake recreational Environmental Ongoing or subsistence fishing within the mining area, closed areas and marine protected areas. Fishing and fisheries resources Manager/Contr  Divers should avoid removing and/or damaging rock lobsters when operating suction pipes Poaching actor Manager during mining. 3. OPERATIONAL PHASE: Vessel-based diver-assisted mining

3.1 Environmental Raise awareness in  An Environmental Code of Practice (ECOP) must be prepared for each contractor. The ECOP Environmental Ongoing will be specific to each operational area and will include Responsibility contractors Manager/Contr  Environmental considerations (i.e. identification of sensitive receptors) and establishment actor Manager of no-go / restricted areas  Site location and demarcation of the extent of the mining concession  Housing keeping:  Tailings discard requirements  Bunding of fuel stores  Waste management, including the removal of all facilities, waste and other features established during mining activities  Establishment of a rehabilitation fund  Monitoring  Before the commencement of any work on site, the contractor's site staff must attend an environmental awareness-training course presented by the Manager/Officer. The contractor must keep records of all environmental training sessions, including names of attendees, dates of their attendance and the information presented to them.  Prior to a contractor leaving a site and/or moving to a new site, the area must be audited by the Environmental Manager/Officer. Only once the Environmental Manager/Officer is satisfied that the area has been suitably cleaned and rehabilitated should the rehabilitations funds be paid back to the contractor.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

3.2 Mining in Minimise impacts on  Mining of any nature should not be permitted in nearshore habitats (with restricted representation) identified as critically endangered by the SANBI’s National Biodiversity nearshore nearshore reef Assessment (Sink et al. 2011) (Namaqua inshore reefs). If, however, prospecting / mining is environments communities and proposed within these areas an independent assessment of the habitats and associated biota sensitive areas should be undertaken by a suitably qualified ecologist to verify the habitat status. Should it be confirmed that the habitats are in deed ecologically unique, these areas should be declared ‘no- go’ / restricted areas and any future prospecting / mining there should be prohibited.  In the case of Namaqua Inshore Hard Grounds, Namaqua Mixed Shores and Namaqua Sandy Inshore habitats, which are represented by more extensive areas, the area disturbed annually by mining should be limited to 1% of the available habitat within the mining licence area unless the habitat is confirmed to be different by a suitably qualified ecologist.  Use should be made of existing geophysical data to conduct a pre-mining geohazard analysis of the seabed, and near-surface substratum to map potentially vulnerable habitats and prevent potential conflict with the mining targets. The SANBI benthic habitat maps should be incorporated into the company’s GIS mapping so as to identify potential overlap of current and future mining targets with endangered and critically endangered habitats. This information should be included in the ECOP for contractors. Mineral 3.3 Facilitate natural  Vessel operators should as far as possible position the vessel in such a way that tailings are Contractor Ongoing Processing and discharged back into mined out gullies or into areas of unconsolidated sediment adjacent to recovery Manager tailings mining targets discharge

3.4 Recreational Management of  Do not collect any shellfish (including abalone, rock lobster, mussels) or undertake recreational Environmental Ongoing or subsistence fishing within the mining area or the McDougall’s Bay rock lobster sanctuary. Fishing and fisheries resources Manager/Contr  Divers should avoid removing and/or damaging rock lobsters when operating suction pipes Poaching actor Manager during mining. 3.5 Vessel Avoid pollution of  Ensure good housekeeping practices are in place on all vessels. This should include : Vessel Master Ongoing  ensure all hazardous substances and stocks (e.g. diesels, oils, detergents etc) are stored operations the marine in secured and dedicated storage areas environment  Maintain mining equipment to ensure that no oils, diesel, fuel or hydraulic fluids are spilled  Refueling is to occur under controlled conditions in a harbour only.  Seek to reduce the probabilities of accidental and/or operational spills through enforcement of stringent oil spill management systems. These should incorporate plans for emergencies and Environmental Awareness and Spill Training to ensure the contractors and their staff are appropriately informed of how to deal with spills.

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3.6 Accidental Loss Removal of marine  Remove all redundant buoys and buoylines, Contractor Ongoing  As far as possible retrieve any lost equipment. of Equipment hazards Manager

3.7 Generation of Minimise  Develop and implement a waste management system for ALL diver-assisted mining vessels Contractor Ongoing that addresses all wastes generated onboard. This should include: Wastes operational Manager  Compliance with MARPOL 73/78 standards discharges from  Adequate storage of wastes onboard and subsequent disposal at a recognised waste vessels disposal site;  Separation of wastes on site  No disposal of food wastes overboard;  Recycling and re-use of wastes where possible;  All wastes (including galley wates) must be returned to shore for disposal at a licenced waste disposal site.  Ensure that all mining vessels that stay out overnight have sewage holding tanks, and that sewage is diluted with seawater prior to discharge. Vessels too small for holder tanks should consider installing chemical toilets.  Treatment of wastes at source (treatment/storage of sewage and oily water separation).  Implement a Shipboard Oil Pollution Emergency Plan

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

4. OPERATIONAL PHASE: Cofferdam Operations

4.1 Environmental Raise awareness in  An Environmental Code of Operational Practice (ECOP) must be prepared for each contractor. Environmental Ongoing The ECOP will be specific to each operational area and will include Responsibility contractors Manager/Contr  Environmental considerations (i.e. identification of sensitive receptors) and establishment actor Manager of no-go /restricted areas  Site location and demarcation of the extent of the processing area, and access routes  Housing keeping:  Use of drip trays under stationary plant and for refuelling and maintenance activities  Use and maintenance of toilet facilities  Bunding of fuel stores  Demarcation of refuelling and maintenance areas  Waste management, including the removal of all facilities, waste and other features established during mining activities  Rehabilitation specification (if necessary), e.g. topsoil management, reshaping, netting, etc.  Establishment of a rehabilitation fund  Monitoring  Before the commencement of any work on site, the contractor's site staff must attend an environmental awareness-training course presented by the Manager/Officer. The contractor must keep records of all environmental training sessions, including names of attendees, dates of their attendance and the information presented to them.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

4.2 Construction of Minimise impacts in  Prohibit mining of any nature in the: Contractor Ongoing  Endangered Namaqua Mixed Shore habitat. cofferdams the coastal zone Manager  Critically endangered Namaqua Sheltered Rocky Coast habitat. and intertidal area  If, however, prospecting or mining is proposed within these areas an independent assessment of the habitats and associated biota should be undertaken by a suitably qualified ecologist to verify the habitat status.  Should it be confirmed that the habitats are indeed ecologically unique, these areas should be declared ‘no-go’ areas and any future prospecting or mining there should be prohibited.  Limit the number of cofferdams operational concurrently.  Use materials sourced locally from old tailings dumps for cofferdam construction and avoid using quarried material where possible.  Mine each block sequentially to completion, with only two adjacent blocks active concurrently.  As soon as a block has been mined out, remove cofferdam material from the beach as far as wave action will allow and re-use this material during further construction. For cofferdams located on rocky shores, remove cofferdam material as far as possible from gullies and potholes. 4.3 Vehicle and Avoid pollution of  Ensure good housekeeping practices are in place at all shore-based operations. This should Contractor Ongoing include : machinery the coastal and Manager  Place drip trays under all stationary machinery, operations marine environment  Bunding of all fuel storage areas,  Restrict vehicle maintenance to the maintenance yard area, except in emergencies when the beach area may be used if absolutely necessary,  Maintain mining equipment to ensure that no oils, diesel, fuel or hydraulic fluids are spilled  Refueling is to occur under controlled conditions only.  Seek to reduce the probabilities of accidental and/or operational spills through enforcement of stringent oil spill management systems. These should incorporate plans for emergencies.  On completion of operations at a mine site, remove all facilities, waste and other features established during mining activities or for accessing a mining site.  Clean up and remove discarded equipment, or abandoned structures as part of responsible environmental management in new or renewed operations.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

4.4 Mineral Facilitate natural  All tailings generated must be used to back-fill mined out blocks. Environmental Ongoing  Confine stockpiles and processing of ore to mineral processing areas and limit the separation Processing and recovery Manager/Contr process to a specific controlled area. tailings actor Manager discharge

4.5 Generation of Prevent littering and  Ensure that all solid wastes generated at the campsite and mineral processing area are Environmental Ongoing disposed of in relevant containers and that these be regularly removed to a recognised waste Wastes accumulation of Manager/Contr disposal site solid wastes actor Manager  Remove all derelict and abandoned equipment in the coastal zone 4.6 Shoreline Assessmnet of  To monitor sand accumulation or erosion from the southern and northern limits of individual Environmental Monthly cofferdams, measure the beach profiles to the north and south of cofferdam operations on a Monitoring indirect impacts Manager/Contr monthly basis. Profiles should be measured at low spring tide. actor Manager  To quantify the impact of cofferdam mining on intertidal communities and determine recovery rates of the affected biota on cessation of mining, undertake a monitoring programme of intertidal sandy beaches and rocky shores in the licence area adopting a before-after/control- impact (BACI) sampling approach that provides spatial replication within each habitat and temporal replication at different times after mining. Details are provided in the monitoring plan (see Section 7) 5. OPERATIONAL PHASE: Mid- and Deep-water Operations

5.1 Environmental Raise awareness in  An Environmental Code of Practice (ECOP) must be prepared for each contractor. The ECOP will be specific to each operational area and will include specifications for: Responsibility contractors  Environmental considerations (i.e. identification of sensitive receptors) and establishment of ‘no-go’ / restricted areas  The mining target area  Waste management (including tailings discard requirements)  Rehabilitation specifications (including monitoring requirements by the Mining Licence holder)  Establishment of a rehabilitation and recovery fund  Undertake Environmental Awareness Training to ensure the vessel’s personnel are appropriately informed of the purpose and requirements of the EMPr.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

5.2 Mining Minimise impacts on  Use existing geophysical data to conduct a pre-mining geohazard analysis of the seabed, and Mine Planner Ongoing near-surface substratum to map potentially vulnerable habitats and prevent potential conflict rocky outcrop with the mining targets. The SANBI benthic habitat maps should be incorporated into the communities company’s GIS mapping so as to identify potential overlap of current and future mining targets with endangered and critically endangered habitats. This information should be included in the ECOP for contractors.  Avoid targeting areas of unconsolidated sediments in close proximity to rocky outcrop areas identified by the pre-mining geohazard seabed analysis. This should include a suitable buffer zone around identified sensitive areas to ensure that these are not affected indirectly by plume impacts.  Mining targets that overlap with critically endangered Namaqua sandy inshore habitat must ensure that the area disturbed annually does not exceed 1% of the available habitat withing the mining licence area, unless the habitats are confirmed to be different by a suitably qualified ecologist. 5.3 Generation of Minimise  Ensure compliance with MARPOL 73/78 standards Vessel operator Ongoing  Develop and implement a waste management system for ALL mining vessels that addresses all Wastes operational wastes generated onboard. This should include: discharges from  Separation of wastes at source; vessels and ‘walk-  Recycling and re-use of wastes where possible; in’ platforms  Treatment of wastes at source (maceration of food wastes, compaction, incineration, treatment/storage of sewage and oily water separation).  If wastes are incinerated on board ensure that an Atmospheric Emissions Licence is in place.  All hazardous wastes must be brought to shore for licenced disposal  Dechlorinate sewage effluents and cooling water to World Bank standards for residual chlorine. 5.4 Night-Time Minimise increase in  Where feasible, shielding operational lights in such a way as to minimise their spill out to sea Vessel operator Ongoing  Record information on patterns of bird reaction to lights and real incidents of injury/death, Operations ambient lighting including stray land birds resting on the rig, during the drilling operation  Keep disorientated, but otherwise unharmed, seabirds in dark containers for subsequent release during daylight hours. Injured birds should be humanely euthanised. Ringed/banded birds should be reported to the appropriate ringing/banding scheme (details are provided on the ring).

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

5.5 Accidental Loss Removal of marine  Establishing an offshore hazards database listing the type of gear left on the seabed and/or in Vessel operator Ongoing the licence area with the dates of abandonment/loss and locations, and where applicable, the of Equipment hazards dates of retrieval.  As far as possible retrieve any lost equipment. 5.6 Crew Transfers Minimise noise  Implement relevant policies and procedures to manage noise generation by and flight paths for Aviations Ongoing helicopters impacts on coastal Manager  Flight paths must be pre-planned to ensure that no flying occurs over coastal reserves and marine fauna (MacDougall’s Bay), seal colonies (Buchu Twins, Kleinzee and Strandfontein Point), bird colonies (Bird Island at Lambert’s Bay) or Important Bird Areas (Orange River Mouth wetlands).  Avoid extensive low-altitude coastal flights (<2,500 ft and within 1 nautical mile of the shore), particularly during the winter/spring (June to December) whale migration period and during the November to January seal breeding season.  The flight path between the onshore logistics base in Alexander Bay and mining vessel should be perpendicular to the coast. As no seasonal patterns of abundance are known for odontocetes occupying the proposed exploration area, a precautionary approach to avoiding impacts throughout the year is recommended.  Aircraft may not, without a permit or an exemption, approach to within 300 m of whales in terms of the Marine Living Resources Act, 1998, without a permit. As this may be both impractical and impossible, an exemption permit must be applied for through the Department of Environmental Affairs;  Contractors should comply fully with aviation and authority guidelines and rules;  Brief all pilots on the ecological risks associated with flying at a low level along the coast or above marine mammals.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

6. REHABILITATION AND CLOSURE PHASE

NOTE: Formal rehabilitation of the seabed below the low water mark is not possible, as sediment and organisms are redistributed effectively by natural water movements

6.1 Planning for Optimising the post  Ensure that plans for rehabilitation, and provision of resources to achieve these, form an Environmental Before start integral part of mining planning from start-up. This should include: Closure mining land/seabed Manager of operations  Identify all necessary guidelines for mitigation of negative effects including the removal of use potential abandoned equipment and garbage, minimisation of air and water pollution, tailings/ soil handling, re-establishment of benthos/ vegetation  Plan for the demolition and/or removal of all structures and debris on cessation of mining activities, and the restoration of the land surface above HWM  Clearly allocate timing and responsibility for rehabilitation to mine operators and/or contractors 6.2 Campsites and Optimising the post  On completion of operations at a mine site remove all facilities, garbage dumps and other Environmental features established during mining activities or for accessing a mining site. Processing mining land/seabed Manager  Clean up and remove discarded and derelict equipment, or abandoned structures from the Areas use potential coastal zone and intertidal areas  Remove contaminated soil from vehicle maintenance and processing areas and either dump it at a recognised land based disposal site or process it by bio-remediation  Flatten uncontaminated mounds or heaps of other material, other than topsoil and subsoil, to reduce visual impacts  Refill excavated areas (e.g. quarries, landfill sites)  Level the disturbed area to a condition resembling its natural profile. Scarify the surface of soil compacted areas to maximise potential for collection of fog, for moisture, and windblown seed in pockets to serve as regeneration and dispersal nodes.  Prior to a contractor leaving a site and/or moving to a new site, the area must be audited by the Environmental Manager/Officer. Only once the Environmental Manager/Officer is satisfied that the area has been suitably cleaned and rehabilitated, tailings dumps and cofferdam walls have been removed, and area reshaped back to natural topography will the rehabilitations funds be paid back to the contractor. 6.3 Roads and Optimising the post  Place barriers (e.g. rocks, fences) to the entrances of non-essential and redundant informal Environmental tracks and signpost intention to rehabilitate. tracks mining land/seabed Manager  Where the surface of redundant tracks has become compacted, plough or rip the surface and use potential temporarily stabilise with mulch until suitable vegetation establishes itself.

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Monitoring and Ref. Environmental Timing / Activity: Management action: Responsibility: record keeping No. objective: Frequency: requirements

6.4 Beach mining Optimising the post  Backfill all beach excavations with the excavated material as mining progresses in such a way Environmental as to maintain the original beach profile as far as possible mining land/seabed Manager use potential

6.5 Cofferdam Optimising the post  Backfill all coastal excavations with the excavated material as mining progresses in such a way Environmental as to maintain the original beach profile as far as possible mining mining land/seabed Manager  As soon as a block has been mined out, remove cofferdam material as far as possible and re- use potential use this material for backfilling. 6.6 Removal of Optimising the post  Ensure that all solid wastes generated at the campsites and mineral processing areas are Environmental Ongoing removed and disposed of at a recognised waste disposal site Wastes mining land/seabed Manager/Contr  Remove all derelict and abandoned equipment in the coastal zone use potential actor Manager

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Ref. Licence Area: Habitat Monitoring recommendations No. 7. ENVIRONMENTAL MONITORING Environmental Objectives:  Gather area-specific biodiversity data at both mined and undisturbed sites.  Develop an information base that will provide improved insight into the potential deleterious effects of the various mining approaches on marine benthic communities and subsequent recovery therefrom. 7.1 Licence 554MRC Intertidal Rocky Shores  Undertake a once-off survey of intertidal rocky shores at ten representative sites in each of the concession areas (1A, 2A and 3A) to determine the species diversity, percentage cover and abundance of benthic macrofauna and macroalgae.  The survey should include sampling at unmined, currently mined and historically mined sites.  At each site survey six quadrats placed equidistantly along each of five transects set perpendicular to the shore from mean low-water spring to mean high-water spring-tide levels.  Record species as primary and secondary cover, and count all rare and mobile species.  Surveys must be conducted during suitable spring low tide periods.  Investigate the relationship of benthic community structure with time since mining.  If possible, undertake a follow-up survey five years after the once-off baseline using the same sampling approach. 7.2 Licence 554MRC Intertidal Sandy Beaches  Undertake a monitoring programme of intertidal sandy beaches in the licence area adopting a before-after/control-impact (BACI) sampling approach (if possible) that provides spatial replication within each beach and temporal replication at different times after mining.  To quantify the impact of cofferdam mining on intertidal invertebrate macrofaunal communities, sampling should be undertaken at two sites per mining target and two control sites that will remain undisturbed for the duration of the monitoring programme.  The surveys should include sampling at unmined, currently mined and historically mined sites throughout the licence area.  At each site measure beach gradient, particle size, wave height and frequency, effluent-line crossings and surf zone width.  At each site take replicate samples at each of 10 stations equidistantly spaced between the drift line to the low water mark along three transects.  Identify macrofauna to species level (where possible) and determine the species diversity, and the abundance and biomass for each species.  Surveys must be conducted during suitable spring low tide periods.  The initial pre-mining survey must be conducted annually, at the same time each year, for two consecutive years prior to mining.  The post-mining surveys must be conducted annually at the same time of the year for the first three years; and then again at year 5 and 7.

 If the BACI approach is not possible (i.e. control sites cannot remain undisturbed for the duration of the monitoring programme), then sample at unmined, currently mined and historically mined sites throughout the licence area to investigate the relationship of invertebrate macrofaunal communities with time since mining.  Sample eight representative sites, of which two much be unmined.  At each site the sampling approach will be as for BACI approach described above.  Surveys must be conducted annually at the same time of year, for a period of at least 3 consecutive years. 7.3 Licence 554MRC Intertidal Sandy Beaches  Monitor sand accumulation or erosion by measuring beach profiles at the southern and northern limits of individual coffer dams  Profiles must be measured at low spring tide on a monthly basis

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Ref. Licence Area: Habitat Monitoring recommendations No.

7.4 Licence 554MRC Offshore Unconsolidated  Implement a before-after/control-impact (BACI) benthic monitoring programme to quantify the spatial and temporal impact of mining on benthic invertebrate macrofauna community composition and to demonstrate natural recovery processes. Sediments Licence 513MRC  In doing so collect biological baseline information on the spatial distribution and variability of the benthic macrofaunal communities and sediment Licence 10025MR structure in and around mining target areas, prior to the commencement of mining.  The number of monitoring sites will depend on the final mine plan configuration.  At each site, 10 replicate samples must be collected with a Van Veen grab deployed off a suitable survey vessel.  The volume of each grab must be estimated and a sediment sample removed for granulometry, organic matter (carbon) and trace metal analyses.  Organisms are to be identified to the lowest taxonomic level possible and the abundance and biomass of each species recorded.  Baseline data should be collected at the same time of year, annually for at least two (preferably three) years prior to the commencement of mining.  Post mining recovery monitoring should commence within three years of the last sampling campaign and continue every third year to year 12 or until communities have recovered to at least 80% of the measured pre-impact baseline levels, and remained at this level for at least 3 consecutive years.  Once initiated, monitoring should be conducted annually or biannually until macrobenthic communities reach at least 80% of the measured pre- impact baseline levels, and remain at this level for at least three to five years.

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